The question is, why is that even the question? How sick and wrong is it to have a discussion that basically amounts to, "but can I still get away with this - how about this - how predatory am I allowed to be"? How fucking warped a perspective is that to have on sex? Making it about victory and conquest and some kind of battle between the involved parties, where one's trying to get it and the other's trying to keep it? Consent should never be a question. If you have any reason to think that your prospective partner might not want to have sex with you, why are you trying to get it anyway? Why should the lies even come into it?
That said, there's a huge difference between "withholding personal information from a sexual transaction that does not involve that information" and "relying on false information to get someone into bed." If Chameleon had tried to pick up an anonymous stranger in a bar while wearing Peter's face, no, that's not a particularly rapelike act. He's withholding information, but it's not relevant information. Whoever he goes home with consented to sleep with *him*.
This woman consented to sleep with Peter Parker. Someone she knows. For reasons that involve, very clearly, who Peter is as a person, and not who Chameleon was when they met. That is very different, and very much rape.