GDPR: Does Air directly or indirectly store data in the iCloud?

Hey guys,

to be compliant with the new GDPR and Apple policies, apps must provide a way for users to download their data that an app stored in iCloud and / or delete that data upon request [1]. We are not at any time storing any data to iCloud directly. But if I remember correctly, there were certain directories on the device that might have been synced automatically to the iCloud when an app stores files or data in them. Can anyone confirm that this is true or point out which directories are synchronized with the iCloud?

Thanks in advance

[1] https://developer.apple.com/support/allowing-users-to-manage-data/