Nore the part where the guidelines state:
"Only include this functionality if you’ve fully vetted your legal obligations everywhere you make your app available and are prepared for extra time during the review process."
That's where you stand. Pessimistic people reading this thread are going to suspect that you haven't fully vetted your legal obligations (that is, gotten professional paid legal advice that you are following on this matter) and aren't prepared for Apple to look at what you've done, spend extra time reviewing it, and then tell you that you've made a mistake and need to make changes.
At this point you're asking people who aren't legal professionals to tell you whether what you're doing is going to be okay, ignoring important details such as:
- You aren't identifying where you are and where this would be legal
- You aren't providing the specific details needed to verify that what you want to do would work or be legal in your jurisdiction
- Apple doesn't do pre-reviews. You have to build the system you're planning on using, and then submit it for review. "Is this going to be approved?" doesn't work outside of the trivially bad idea cases where the answer is "No, that's not okay."
There are any number of things that you could do incorrectly that would render your app either illegal or just rejected, even if the concept that you're proposing is legal in your current jurisdiction. Please explain how you've accounted for all of those possibilities.