Apple app rejection due to Guideline 3.2.1(viii)

Hi,

I work for UK company Lendable: https://www.lendable.co.uk/about

Lendable Ltd, company number 08828186 (previously Feather Media Ltd). Authorised and regulated by the Financial Conduct Authority (FCA). We are registered with the Information Commissioner’s Office in compliance with the Data Protection Regulations 2018 under registration ZA041704. Registered office at Lendable, Telephone House, 69-77 Paul St, London, EC2A 4NW.

At the moment our Zable app is being constantly rejected for Guideline 3.2.1 (viii) - which I quote below:

Business - Other Business Model Issues - Acceptable

We continue to notice that your app provides loan services but the domains listed on the app's Product Pages are not clearly under your control or ownership. Since users may use these domains to contact you to request support, the domains used on the Product Page for loan apps must be under your control or ownership.

Next Steps

Update the Product Page metadata in App Store Connect to only include domains that are associated with Apple Accounts registered to your developer account.

Please note that apps used for financial trading, investing, or money management should be submitted by the financial institution performing such services, as required by App Review Guideline 3.2.1(viii).

Zable is a fully owned Trading name of Lendable Operations Ltd. We fully own the name, domain, website and app associated with the name Zable (zable.co.uk and zable.com).

zable.co.uk universal links are verified within our developer account and the app responds correctly to opening them.

In the app review process we have provided legal documents showing our company structure and how Zable is a fully own trading name of Lendable Operations Ltd.

We have asked multiple times what further evidence we need to provide to ensure the trading name Zable is allowed to provide loan products for Lendable Operations Ltd on the app store. We are simply told the domain is not verified.

It has been an extremely frustrating process. How further can we verify the domain? What do we need to do?

Please help.

I don't know what they require, but can you clarify

  • Which domains are in the app description etc? Is that zable or lendable?

  • Which domains are shown in the app itself?

  • Is your developer account name Zable or Lendable?

You might also consider removing the "privacy protection" on your domain registrations, so that whois queries return something resembling your correct physical address. I don't think Apple will be using that but it could be considered good practice anyway.

Additionally, I went to both zable.co.uk and zable.com websites.

zable.com says nothing about "Lendable" and clearly says it is separate company. That alone appears to be the practice that this policy was designed to prevent.

The zable.co.uk site does say that it's a trading name of Lendable, albeit with a copyright of "Zable". I don't know if that disclaimer is sufficient to satisfy Apple's policy for this site.

Maybe you should partake of Apple's one-on-one App Store consultation?

Weird - first timer on this site and thought my comment replies to you above would appear for everyone. Seems they are just for the person I'm responding too. I'll summarise below.

@endecotp The app description, privacy and support links for the Zable app in the app store all point to zable.co.uk. Our app store connect account is under Lendable - but this is the actual company and only legal entity we could use - due to the requirement of a having a DUNS number etc. We couldn't set the account to be zable as that is just a trading name.

Equally we can't change the details in the app description as the loans are sold under the name zable and the website is where we need to direct support queries etc.

Its a good shout about the privacy protection on the whois lookup, but I would hope that the app review process would tell us if that was needed.

@Etresoft I got confused on zable.com. That is actually our US trading brand and that falls under our US entity Zendable (no idea who was in charge of naming these things). So ignore that one for now.

As you say the zable.co.uk site does say in the footer, privacy policy and a few other places that Zable is a trading name of Lendable.

I did apply for a one to one store consultation yesterday and was rejected. They don't specify why. FWIW I asked to discuss the guidelines we are talking about here.

We did just get approved with no explanation and no changes, after a total of 7 app version rejections including weeks of daily back and forth with app review.

We still don't understand what made them accept the previously rejected app with no changes. This does not give us much faith this issue won't keep happening again.

We did contact our UK apple business manager and ask if they had any connections with app review to help us get to the bottom of the issues. They initially said they were not able to help but did respond saying it had been escalated this morning so maybe that was it.

The only other thing it conceivably could be was a change to our app verified domains. We have used a subdomain for universal links of zable.co.uk (as in app.zable.co.uk - which is just a rewrite of the root zable.co.uk) since the app was first uploaded without issue, but we are thinking maybe the app passed because we added the root zable.co.uk as a verified domain as well as the subdomain?

Its a pain because now we need to exclude all routes that aren't to do with app linking rather than just include the ones that do. But seeing as Apple are as opaque about what is actually the problem with all this stuff - we are just left guessing.

I'm glad you got it fixed.

I think it probably comes down to your account being "Lendable" and the app store metadata description mentioning "Zable" and Apple not (initially) being able to tie those together.

It's quite possible that the issue will recur. There's not much you can do about that, unfortunately. Opaque, non-specific replies from Apple without any possibility of elaboration are to be expected.

Apple app rejection due to Guideline 3.2.1(viii)
 
 
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