I would have thought that DRM is a loophole you can drive a truck through. As long as any of your data is of value, you can claim the reason for encryption is DRM. Even if you let the end user have access to all data, you could always send some sort of DRM heartbeat.
No loophole! It only count's if you exclusively need encryption for DRM. Not for other stuff like, to protect your users chat communication for example.
