Yes, in the same way that tomatoes meet the definition of a fruit. (And before you say "but tomatoes are a fruit"—exactly.†)
I respect your desire to be precise, but the problem is that it makes conversations super difficult. Detailing Apple's convoluted policies every time the topic comes up is tiresome and needlessly derails the conversation.
† See also: https://www.youtube.com/watch?v=XmxIK9p0SNM