An important question

It is masturbating to orgasm.

 

I guess so, but you're making it only harder for yourself.
The most important thing, though, is not how others define the word "Fapping" - important is, that YOU yourself have a clear conscience about YOUR rules and how you've been following them.

First of all, ask yourself: why do you want to rub your nuts - if you've got an itch, there - fine, help yourself. But if it makes you feel good, it's because your dopamine starts flowing, and that's essentially the same thing like teasing your glans. Which is something you'll want to avoid at all costs. With me, now occasionally (while I'm no on NoFap) that happens unconsciously (when I'm alone at home and watching a movie, for example) - so, as soon as you notice your hands sliding into your underpants, stop right there, and you're golden.