I'm not sure the guidance applies in this case, as this technique is an edge case which the writers probably didn't foresee. The ePrivacy directive itself has

I'm not sure the guidance applies in this case, as this technique is an edge case which the writers probably didn't foresee. The ePrivacy directive itself has in article 3.1: This Directive shall apply to the processing of personal data [...] which would mean it doesnt apply here, as there is no personal data. In practice, I assume this one is for the judges.