No, IP address is personal data by the EU definition and you need a legal basis to process it. The strictly necessary legal basis allows for TCP connections req

No, IP address is personal data by the EU definition and you need a legal basis to process it. The strictly necessary legal basis allows for TCP connections required to provide the requested service. It is clear that the EU does not consider telemetry to be strictly necessary and while there can be times when telemetry is allowable with the legitimate interest legal basis (for example, to prevent fraud or to comply with legal obligations), there is already plenty of case law across the EU that shows that the legitimate interest legal basis will not be accepted for user analytics. For this reason, it seems unlikely that the proposed telemetry will be compliant in the EU.