Q: Can you literally give away free things to kick start your project / startup?

CONTEXT:

• We have a free app that aims to encourage people to help 1 another
• You can get rewarded with free points if you help others
• You can redeem those points for rewards (currently set to be restaurant gift cards)

MY Q/CONCERN:

• We are doing a relaunch where if you are on the launch list you are automatically awarded X # of points, which = X $ amount of gift card instantly (after you redeem it in the ap)
• In this case, I don't think we're a sweepstake since it's not a 'chance' that you enter to win
• There's no purchase required by user (heck, they don't even have to sign up, our service does not require an account)

So legally can we do this? Just give stuff away to incentivize people to hop on and use the app in the beginning. Wondering if anyone on IH has experience they can share with running similar promotions or campaigns. Thanks!!!