[chrismcb]

>... Any valid, submitted application...

Didn't you answer your own question? They claim if you use their service then your application will participate, this they are claiming your application will be valid and submitted. Id you don't use their service then there is a chance your application will not be valid or submitted... Isn't that a positive? Maybe not enough of a positive to justify the cost, but their claim isn't unethical.

[sdhgaiojfsa]

I doubt they have the capability to cause whatever information you provide to magically become valid. Perhaps they do additional checking and notify you if there is an error. If that is what it is, then that is what they should say. The sentence as worded implies that any application has some chance of not participating in the lottery if made through ordinary channels.