Earlier quoted context omitted.
> Anomyous telemetry is not PII. That depends. First, no data collection is "anonymous" when it is transmitted. Any anonymity must come later, and then is only possible if the company aggregates the data with other users and deletes the original data that was collected. PII/Personal Data are squishy terms. In the US, anyway, the legal definitions of what counts as "PII" leaves out an awful lot of actual PII -- so any…
> First, no data collection is "anonymous" Because no network connection is anonymous but as long as you aren't handling PII, GDPR has nothing to say about it. I could sell an app in the EU that just pinged my server once a day. As long as I wasn't keeping a record of who pinged what when, there is no PII. Otherwise everything is PII and you would need consent before every TCP handshake.
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.