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I want to release my first app to Google Play and App Store. I have a question about Export Compliance issue. Since I didn't even know this is needed I am struggling. I already posted a similar question to the Stackoverflow but there's not a lot of action going on as it is more of a legal matter. I also asked on the Unity Forums (link below) and contacted Apple support but they can't help me with legal matters.

I made the game using Unity, and I am using Unity IAP for in-game purchases and Unity Ads. IAP uses ASN.1 and SSL for making purchases only (more about that on the Unity forums link). Since I didn't add any encryption on my own into the game and answers on Unity Forums are mixed, could someone please help me with an answer to those 2 questions in app store and do I need to do anything additional?

I can't post images so I am copying the text.

First question:

Export Compliance Information. Does your app use encryption? Select Yes even if your app only uses the standard encryption within Apple’s operating system.

If the answer to first is yes, this is the second one

Does your app qualify for any of the exemptions provided in Category 5, Part 2 of the U.S. Export Administration Regulations?

Make sure that your app meets the criteria of the exemption listed below. You are responsible for the proper classification of your product. Incorrectly classifying your app may lead to you being in violation of U.S. export laws and could make you subject to penalties, including your app being removed from the App Store.

You can select Yes for this question if the encryption of your app is: (a) Specially designed for medical end-use (b) Limited to intellectual property and copyright protection (c) Limited to authentication, digital signature, or the decryption of data or files (d) Specially designed and limited for banking use or “money transactions”; or (e) Limited to “fixed” data compression or coding techniques

You can also select Yes if your app meets the descriptions provided in Note 4 for Category 5, Part 2 of the U.S. Export Administration Regulations.

Unity Forums: click me

If anyone could help me with the answers I would really appreciate it as I am not from the US and this is really giving me a headache. Thank you!

  • So, what’s your question? – Dale M Sep 14 '19 at 22:57
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    Your lawyer should be answering any questions about compliance. If you don't have a lawyer, your first step is to get one. – Nij Sep 14 '19 at 23:20
  • The questions are the two yellow quotes. What should I answer to it and do I need to do anything further. Also, I understand that I would need a lawyer but I'm asking here if anyone knows this or have done something like this because I am not some major corporation or someone who's intention is to make the big bucks with the app. I just don't want any legal troubles :/ – Matija Tersek Sep 15 '19 at 10:24
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I am not a lawyer, I’m an IT guy. As a result, you shouldn’t consider this legal advice; talk to an actual lawyer.

That said, it sounds like you should be fine. The Unity IAP is the only encryption your game has, and it is for handling in-app purchases, right? Take a look at exception (d) in your quote:

(d) Specially designed and limited for banking use or “money transactions”;

It sounds like in-app purchase functionality would qualify for that.

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