They should say "for Android apps". Boom. Makes more sense. I'm sure there are other phrasing tweaks that would also work.

But it's just like Microsoft to blindly settle on a name that doesn't make sense, based on advice from legal, and not probe it a bit more, or play with it to make more sense while still fitting the guidelines of legal advice, and to cite the legal guidance as the reason it has to be mediocre and cannot change. (Source: I once worked for MS.)

Edit: to be clear, I'm also reacting to the "windows subsystem for Linux", which they used the same justification for.