It might fit under one of the following exclusions, particularly noting that the company is a promotional and marketing company:
“supplied to a purchaser of goods or services as part of a temporary marketing promotion (e.g. a wine voucher valid for one month that is mailed to a consumer as a free bonus with a purchased item and was not part of the purchase offer)”
or
“donated free of charge for promotional purposes (e.g. a local shopping centre has a one-day marketing promotion where each visitor to the centre on that day is handed a $20 gift card that is valid for use at any store in the centre for that day only)”
As we aren’t legal experts here, we can only offer personal opinion. In this case you may be best served by contacting a free Consumer Law service and getting a legally qualified opinion. We have a small list for each State/Territory of free centres that should be able to give you guidance. Free Legal Advice Centres
