I am planning an iOS app for strength training, nutrition and sleep. Before I build the data layer I would like to understand how Apple reads the following rules. Planned design: Body measurements and sleep values live in HealthKit only and are never written to iCloud or CloudKit. Training sessions and meal entries (food, calories, macronutrients, entered manually or by barcode scan) are stored on the device and in the user's private CloudKit database. Nothing is stored on our own servers. The app also caches packaged food products the user has scanned (name, ingredients, allergens, nutrition facts from the public Open Food Facts database) in the same private CloudKit database. Guideline 5.1.3(ii) says apps "may not store personal health information in iCloud", and DPLA 3.3.3(D) restricts using iCloud or CloudKit for "sensitive, individually-identifiable health information" unless Apple permits it in writing. Questions: Does a meal log or a product cache in the user's private CloudKit database count as "personal health information" in this sense, as long as no HealthKit values are stored there? Is the answer different if the private CloudKit data is end-to-end encrypted (encryptedValues)? I understand that App Review cannot pre-approve an app. I am only asking how the rule is meant to be read. Thank you.

Guideline 5.1.3(ii) and DPLA 3.3.3(D): private CloudKit for meal logs and workout logs (no HealthKit values)?

I am planning an iOS app for strength training, nutrition and sleep. Before I build the data layer I would like to understand how Apple reads the following rules.

Planned design:

Body measurements and sleep values live in HealthKit only and are never written to iCloud or CloudKit.
Training sessions and meal entries (food, calories, macronutrients, entered manually or by barcode scan) are stored on the device and in the user's private CloudKit database. Nothing is stored on our own servers.
The app also caches packaged food products the user has scanned (name, ingredients, allergens, nutrition facts from the public Open Food Facts database) in the same private CloudKit database.

Guideline 5.1.3(ii) says apps "may not store personal health information in iCloud", and DPLA 3.3.3(D) restricts using iCloud or CloudKit for "sensitive, individually-identifiable health information" unless Apple permits it in writing.

Questions:

Does a meal log or a product cache in the user's private CloudKit database count as "personal health information" in this sense, as long as no HealthKit values are stored there?
Is the answer different if the private CloudKit data is end-to-end encrypted (encryptedValues)?

I understand that App Review cannot pre-approve an app. I am only asking how the rule is meant to be read. Thank you.