Charity app keeps getting rejected for Guideline 3.2.2 - Business - Other Business Model Issues - Unacceptable

Hi there


We have an app which keeps getting rejected by the app store for 3. 2.2 Business: Other Business Model Issues - Unacceptable


However, I am sure that our business model does not lend itself to the apple pay model and would like to know if anyone can help resolve this.


Here is a description of our model:


In the app, users are able to authorise our company to make future off-session payments on their behalf that are not fixed in date or amount. No payments are made in the app itself.

For all of our users, the app is a way to set or change their choice of charity, method of donating, which payment method is attached to their account and to pause their giving. All payments are handled in a different part of our eco-system, outside of the app. This aligns with a key value we hold, which is that giving to charity should be frictionless and effortless. Our entire model is built with the intention that once registered, a user can support their charity without returning to the app, eg. by every day card purchases being rounded up and triggering an off-session payment to their charity. The user is never present when the payment is taken, and is only ever required to go on-session in the rare event that a new payment requires SCA authorisation.


To summarise:

- Users are not able to make a donation within our app

- All payments take place outside of the app

- At the point the user authorises our company to make future off-session payments, the date and amount of those payments are not finalised and are open to change based upon the user's in-app choices between payments.

We do not handle instant, in app payments and do not handle any money directly, or payments, or card payments directly.

We use Stripe for processing payments and distribute the donations to our registered UK charities through Stripe Connect platform.

All of our payments are off-session, at a date in the future and when processed are sent directly to our registered UK charities through the Stripe Connect platform.

All of our charities are registered on benevity.org.


To give some context, our app is a tech for good app, already live as a webapp and providing a way for everyone to make a positive impact every day - but we want to be in the app store to get a bigger audience at this time and help the charities on our platform.


We have 20 charities on the platform who have seen around 75% of their funding disappear over the past two weeks, since all fundraising events have been cancelled for the forseeable future...and more charities onboarding every day. The situation is only going to get worse the longer the pandemic goes on. Our app is offering a contactless, frictionless way for people to support vulnerable groups through Round Ups and Monthly Happiness. The charities are all verified UK charities and have gone through Anti Money Laundering procedures to get on our platform. We are a source of revenue to them at this time of need - the charities support a range of causes from Alzheimers, to Heart disease, Cancer, vulnerable children and adults in need, such as the homeless.


If anyone can help us natvigate a way through onto the app store that would be so appreciated.


Best regards

Kristina

Replies

Are you an approved non profit organization ?


Read carefully the guidelines to find what to do:


3.2.1 Acceptable

(vi) Approved nonprofits may fundraise directly within their own apps or third-party apps, provided those fundraising campaigns adhere to all App Review Guidelines and offer Apple Pay support. These apps must disclose how the funds will be used, abide by all required local and federal laws, and ensure appropriate tax receipts are available to donors. Additional information shall be provided to App Review upon request. Nonprofit platforms that connect donors to other nonprofits must ensure that every nonprofit listed in the app has also gone through the nonprofit approval process. Learn more about becoming an approved nonprofit.


3.2.2 Unacceptable

(iv) Unless you are an approved nonprofit or otherwise permitted under Section 3.2.1 (vi) above, collecting funds within the app for charities and fundraisers. Apps that seek to raise money for such causes must be free on the App Store and may only collect funds outside of the app, such as via Safari or SMS.

Hi there


Thanks for responding. We are a limited company, but the charities on our platform are all non profits.


Do you know is there a mandate for us to use Apple Pay? We are a limited company and use Stripe to process all donations and send directly to the charities via the Stripe Connect platform. All of our donations are taken off session.


Kristina

As far as I understand, it is not a question of being non profit. It is a question of being Approved nonprofits.


You have to request this approval, by submitting: https://developer.apple.com/apple-pay/nonprofits/

In the document they only mention ApplePay for donations.


Apple Pay for Donations

Apple Pay provides nonprofit organizations a simple and secure way to accept donations from within their app and website. Similar to using Apple Pay to buy goods and services, users can donate without entering their billing, shipping, or contact details.


I also wonder whether having payments outside the app is a helper or a problem for review (understandably, Apple does not take the risk that app may collect money illegally or fraudulously).

>We have 20 charities on the platform - the charities on our platform are all non profits.


Then the question if -you- are an approved non-profit is moot.


>I am sure that our business model does not lend itself to the apple pay model - is there a mandate for us to use Apple Pay?


Seems an odd statement to make without context... If this was suggested via a rejection...pls. share all of them:

  • Did you appeal?
  • If so, what did you say?
  • How many times?
  • How many rejections?
  • What did each rejection say?
  • Were you told to make changes to meta data and not re-submit another build?
  • Were you told to resubmit?


** Note these are simply questions to learn more details about what’s transpired to this point, not suggestions on what you should do next.

-=-

3.2.2 states what is unacceptable:

(iv) Unless you are an approved nonprofit or otherwise permitted under Section 3.2.1 (vi) above, collecting funds within the app for charities and fundraisers.


You are not an approved nonprofit. Section 3.2.1 (vi) requires that "Nonprofit platforms that connect donors to other nonprofits must ensure that every nonprofit listed in the app has also gone through the nonprofit approval process."


So there are two ways forward:

1) satisfy 3.2.1(vi) by assuring that all the listed nonprofits have gone through the approval process and only 'connect donors to' those nonprofits. or

2) do not 'collect funds within the app'.


You believe you are not 'collecting funds within the app'. You could appeal pointing out that you do not 'collect funds within the app'. But App Review may think you are essentially doing that because "users .... authorise our company to make future off-session payments on their behalf..." That authorization may be, in App Reviews opinion, tantamount to 'collect funds'.


So appeal stating that the authorization is not collecting ......or better...... colelct the information within the app but move that 'authorization' off the app by requiring that the user leave the app and go to your website and tap 'I agree' - then point out to App Review that you are neither collecting a payment nor authorizing a payment within the app.

Hello Kristina...I saw this post online and wanted to reply cause I have the same issue with Charities in México...did you find a solution or workaround?
Hi Kristina,

I was looking for similar guidance to yourself in the forum when I came across your plight and wondered if you would mind telling me if you had solved your issue? I am in the early stages of development on an app that cannot run on a website as there has to be a form of tracking so the app is my only option but had flagged that this could be an issue for me too as there is a charity element to my plan but the monies are paid off app to us as a company (limited) and would use Stripe just like yourself. So like you, I can't see an issue but you obviously didn't either!

It doesn't sound like we would be in competition so I hope you don't mind me asking you and I really hope you did find a fix and business is increasing because of the app.

Regards
Hilary

How did everyone end up going with this? I am about to start registering all my non profits on the platform and give them the ability for donations, my organisation is not non profit but it does not take any fees on donations.

The way I read 3.2.1(vi) is that I do not need to be a non profit myself, I just need to:

  1. Go through the Apple non profit approval process for all non profits on the platform.
  2. Provide Apple Pay as a payment option.
  3. Disclose how the funds will be used.
  4. Provide a legit tax receipt.

There seems to be very little information out there on this.

3.2.1 (vi) Approved nonprofits may fundraise directly within their own apps or third-party apps, provided those fundraising campaigns adhere to all App Review Guidelines and offer Apple Pay support. These apps must disclose how the funds will be used, abide by all required local and federal laws, and ensure appropriate tax receipts are available to donors. Additional information shall be provided to App Review upon request. Nonprofit platforms that connect donors to other nonprofits must ensure that every nonprofit listed in the app has also gone through the nonprofit approval process. Learn more about becoming an approved nonprofit.