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I don't ask because I care whether or not it does on some moral grounds. I ask because history is full of apps that circumvented platform structure and then were gone because they were deemed to have violated the platform's terms of service. Some of them were successful before they were gone, though most weren't.
The reason I ask is because an off-platform product with a dependency on Facebook is unlikely survive long/medium term. Long/medium term survival almost certainly will require an entirely off-platform solution. My advice is to build something minimal and quickly and make your users aware of it. Promote it as a feature, so that when Facebook shuts you down, you have a replacement in place.
Good luck.
[1]: Almost certainly, no. If there's a loop hole that you can argue, you'll be arguing it after being shut down. And Facebook can change the TOS anyway.