This should not violate security rules as she's not selling you securities ;).
This clause might be a problem:
the top 100 donations will receive a lifetime premium membership.
If I donate X amount of money, I do not know if I will receive the lifetime membership. I could ultimately be outbid; or I might ultimately not be outbid. It is a game of chance; and unlike in the case of an auction, I pay whether I win or lose. That might make this an unlicenced gambling enterprise.
IANAL, but I would guess that if you are going to offer for sale specified products or services, you need to guarantee that paying customers will receive those specified products or services.