Our app uses the Family Controls framework for individual (self) device management. Separately, it estimates how much a user scrolls from CoreMotion accelerometer data (CMSensorRecorder) with an on-device Core ML model. Today, no Screen Time data leaves the device. We'd like to add an opt-in feature where a user compares results with friends they explicitly invite, and we want to stay within DPLA section 3.3.3(P) ("You and Your Application may not share device or usage data received through the Family Controls Framework or otherwise, beyond … the individual and their device"). Is it acceptable to share, only with invited friends (opt-in), a daily scroll-distance estimate that is computed solely from accelerometer data and never uses DeviceActivity or other Family Controls data? On the device only, we could use DeviceActivityMonitor threshold events to calibrate our accelerometer-based estimate against that user's screen time (the calibration and the threshold data never leave the device). Would sharing the resulting estimate (for example, "estimated minutes") with invited friends count as sharing usage data received through Family Controls, and therefore not be allowed? Would sharing only an outcome derived on device from DeviceActivity threshold events (for example, win/lose or goal met/not met) count as sharing device or usage data under 3.3.3(P)? We understand App Review can't pre-approve features. We're looking for guidance on how to interpret this section.

Family Controls (DPLA 3.3.3(P)): can an opt-in friends feature share a sensor-based estimate calibrated on device?

Our app uses the Family Controls framework for individual (self) device management. Separately, it estimates how much a user scrolls from CoreMotion accelerometer data (CMSensorRecorder) with an on-device Core ML model. Today, no Screen Time data leaves the device.

We'd like to add an opt-in feature where a user compares results with friends they explicitly invite, and we want to stay within DPLA section 3.3.3(P) ("You and Your Application may not share device or usage data received through the Family Controls Framework or otherwise, beyond … the individual and their device").

Is it acceptable to share, only with invited friends (opt-in), a daily scroll-distance estimate that is computed solely from accelerometer data and never uses DeviceActivity or other Family Controls data?
On the device only, we could use DeviceActivityMonitor threshold events to calibrate our accelerometer-based estimate against that user's screen time (the calibration and the threshold data never leave the device). Would sharing the resulting estimate (for example, "estimated minutes") with invited friends count as sharing usage data received through Family Controls, and therefore not be allowed?
Would sharing only an outcome derived on device from DeviceActivity threshold events (for example, win/lose or goal met/not met) count as sharing device or usage data under 3.3.3(P)?

We understand App Review can't pre-approve features. We're looking for guidance on how to interpret this section.