According to some experts in US securities law, if the token being sold gets its value due to its usefulness in an application (e.g. it acts as a currency), it is, in their opinion, legal. If it gets its value from a promise of it providing the holder with a contractual claim on a share of the assets or profits of an enterprise, then it's potentially a security and thus potentially illegal. See the Coinbase securities law framework for more details.

I don't see how your scheme falls into either category. I advise checking with a lawyer before doing anything.