Is It Legal? Yes.
1. A Product Moves.
The Product is The Platform.
2. No obligation to Purchase.
3. You can earn without recruiting.
4. No UK Law that prevents Donation.
5. No UK Law that prevents the Platform being sold forming the vehicle which gifts to others as long as the platform owners derive no income in the gift exchange.
Apart from this its a Mobile Marketing platform that can be configured to your own business requirements.