This is a very simple app. It only handles files twice on startup and then only to load assets and data bundled with the app itself. We have reviewed the code and nowhere is data saved or files or directories created - so iCloud should not be used at all. When we test the app as outlined in 'Next Steps' of the rejection the result is that the app uses 'No Data'.
The details of the rejection are:
2.23 Details
On launch and content download, your app stores 6.8MB on the user's iCloud, which does not comply with the iOS Data Storage Guidelines.
It is a very simple app. Bundled in the applicationstorage is an xml and the bitmap assets. The only file operations made is loading these into the app. we don't save anything anywhere and still - the app is rejected.