yes - but it has to be downloaded by winner separately from UBI. (I can provide a valid downloader)
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private giveaway seems like a good idea. I just have to think of a good puzzle ;)
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Then people will be asking if they can give their Desura keys away officially that came with their Steam copies and that will spam the site while inflating values. Just do a forum raffle for it or something.
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Ask support, they will help you. I saw a Torchlight giveaway with the same "problem" a while ago which had the mod's apporval.
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I asked the support, and sadly it's a no-no. So no giveaway, but I posted a puzzle in another topic, and the first person to solve it, gets the code.
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As in the topic - I have not used and not needed UBI key for AC:Brotherhood and I'm all open to the idea of gifting it (yes, it's legal - I had AC:B from Ubishop and later acquired it on steam, but kept it registered under my old UBI key, leaving me with a spare.)
So the key should be valid and never used - it just won't ever register on Steam, as it is for the UBI account launcher.
Would it break any rules to post it here as a giveaway? It's more fair than simply put it down here for ninjas.
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