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Do I need to use CCATS when using a simple XOR cipher?

iTunesConnect says developers need to get CCATS classification when using in-app encryption. My application uses a simple XF obfuscation cipher when transmitting data over HTTP. Does this still fall under this requirement? If not, what type of encryption should CCATS classify?

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I have no right to offer legal advice.

You probably need to consult with a lawyer to get an answer, since this is a legitimate question.

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