Does this count as a paid random item/gambling?

I’m currently working on a dungeon-crawler type game and I was considering implementing the following system for monetization:

  1. The player buys a dungeon key that grants them one-time access to a randomly generated dungeon with higher loot drop rates
  2. The player plays through the dungeon until they lose or defeat all enemies
  3. As they defeat enemies they drop items of varying rarities

I’m wondering if this would count as a paid random item? I’m assuming it might be because it would be a one time purchase that eventually results in randomized virtual items. Or would the game play element make this count as gambling?

Feedback appreciated, thanks!

It can be both depending on the side you see it.

If you think of it as if the prize is definitly a dungeon:
Then it’s not, because it is a dungeon

If you think of it as if the the prize is a random dungeon:
Then it is.

Both are true!
It depends on which side roblox believes more as true.

From what I gather, you can implement gambling into your game, however you CANNOT be able to convert the currency required for gambling to/from ROBUX.

It is gambling, I assume the key is bought with robux, so yeah.