This is allowed according to the rules http://www.advancedcustomfields.com/resources/including-acf-in-a-plugin-theme/
You can include the ACF PRO plugin within a premium theme/plugin as long as it is made clear in the copyright / information that the ACF PRO files are not to be used or distributed outside of the premium theme/plugin.
Now, just my personal opinion but if you search you’ll find that other share it. Bundling plugins is generally a bad idea because it makes it extremely difficult to update the bundled plugins, or even know that they need to be updated for the person using you’re plugin.
Welcome to the Advanced Custom Fields community forum.
Browse through ideas, snippets of code, questions and answers between fellow ACF users
Helping others is a great way to earn karma, gain badges and help ACF development!
© 2022 Advanced Custom Fields.