I'd be interested in hearing what kind of app it is. Since you're saying that Apple requires already suggests that you do in fact have some connection with user data in some way (I've written a blog post outlining this process).
When I last checked these were the categories:
(i) Apps that collect user data must have a privacy policy and secure
user consent for the collection. This includes—but isn’t limited
to—apps that implement HealthKit or other health/medical technologies,
HomeKit, Keyboard extensions, Apple Pay, include a login, or access
user data from the device (e.g. location, contacts, calendar, etc.).
- (from 5.1.1 in the App Store Review Guidelines)
Moreover, apps in the Kids Category or those that collect, transmit,
or have the capability to share personal information (e.g. name,
address, email, location, photos, videos, drawings, the ability to
chat, other personal data, or persistent identifiers used in
combination with any of the above) from a minor must include a privacy
policy and must comply with all applicable children's privacy
statutes. For the sake of clarity, the parental gate requirement for
the Kid’s Category is generally not the same as securing parental
consent to collect personal data under these privacy statutes.
All of these categories suggest some sort of user data processing.
Regarding the Owner field: yes you're right many countries require basic address and email options there. The easiest way of course to evade putting down your home address is to have some sort of work address available, or non-compliance in that particular element (which of course I can't suggest).
