You’re right of course, but Apple won’t do it - they’re happily running a two-tier system where Uber, eBay, Doordash can force spam notifications on you with impunity. All my settings for marketing are off - eBay still sends me notifications about coupons (and additionally there’s no way to actually contact them to complain, of course). Doordash won’t let me get delivery notifications without marketing notifications.

Apple could fully enforce their policies and fix this in a heartbeat, but they won’t.