In-App Account Deletion: What Counts as Account Creation?

June 30 is the deadline for adding in app account deletion.

I'm unclear whether the app I work on counts as creating an account in the app.

We have several user onboarding flows.

One flow we prepopulate a users profile using a CVS upload to our backend. We provide a deep link that requires the user to set a password in the app, and they can edit some of their prepopulated data. Once they submit they are profile complete.

In other flows we provide a deep link that just has the user's email/phone number and the user's name. We use this to prepopulate a form. The user is asked to select some profile details in this flow as well as provide a password. In this flow the user awaits approval before they can start using the app.

All users can edit profile details once their account is created and once the profile details are all provided.

So, does this count as in app account creation that warrants an in app account deletion flow?

How do I get a definitive answer to this question?

Thanx.

Reference: https://developer.apple.com/news/?id=12m75xbj