Hi, I'm trying to understand how Section 3.3.3(P) of the Apple Developer Program License Agreement applies to the new EU-specific Family Controls App and Website Usage API. Section 3.3.3(P) restricts sharing usage data beyond the individual and their device. However, Apple's documentation for DeviceActivityData.activityData(filteredBy:using:) explicitly mentions exporting activity data for use in another app or platform. Does this restriction still apply unchanged to the new EU API, or are additional uses permitted? I'm also curious whether this capability was introduced as part of Apple's compliance with the EU Digital Markets Act (DMA). I'm particularly interested in two use cases: Private storage: Storing a user's own usage history in their private CloudKit database or in client-side encrypted cloud storage, so their progress is preserved across devices and reinstalls. Voluntary sharing: Allowing users to share locally calculated milestones (e.g., "Alex spent less than 5 hours on Instagram this week") or exact usage times (e.g., "Alex spent 5h 42m on Instagram this week") with selected friends. Each share would require explicit user action and confirmation, with a clear preview of what's being shared. There would be no automatic background reporting or continuous monitoring by friends. I've already contacted Apple's DMA Compliance team and Developer Support, but was directed here without receiving clarification. I'd appreciate any help understanding how the new EU API relates to the existing restrictions, or who I could ask about this. Thanks!

Does DPLA 3.3.3(P) apply to the new EU-specific Screen Time data export API?

Hi,

I'm trying to understand how Section 3.3.3(P) of the Apple Developer Program License Agreement applies to the new EU-specific Family Controls App and Website Usage API.

Section 3.3.3(P) restricts sharing usage data beyond the individual and their device. However, Apple's documentation for DeviceActivityData.activityData(filteredBy:using:) explicitly mentions exporting activity data for use in another app or platform.

Does this restriction still apply unchanged to the new EU API, or are additional uses permitted? I'm also curious whether this capability was introduced as part of Apple's compliance with the EU Digital Markets Act (DMA).

I'm particularly interested in two use cases:

Private storage: Storing a user's own usage history in their private CloudKit database or in client-side encrypted cloud storage, so their progress is preserved across devices and reinstalls.
Voluntary sharing: Allowing users to share locally calculated milestones (e.g., "Alex spent less than 5 hours on Instagram this week") or exact usage times (e.g., "Alex spent 5h 42m on Instagram this week") with selected friends. Each share would require explicit user action and confirmation, with a clear preview of what's being shared. There would be no automatic background reporting or continuous monitoring by friends.

I've already contacted Apple's DMA Compliance team and Developer Support, but was directed here without receiving clarification.

I'd appreciate any help understanding how the new EU API relates to the existing restrictions, or who I could ask about this.

Thanks!