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IP addresses are only PII if attached to other information. I can generate a list of IP addresses and store/sell that data and it's all fine because its meaningless without associated data.

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The other information is "using Atom".

It's still impossible to link that to an individual unless they sold it to another company that has more info on the address.

Or bought the data.

I'm like 99% sure that datasets are available that link IP addresses to all sorts of PII. And then there are third-party cookies and other trackers.

Yes, and that possibility is enough to make this fall under the GDPR.

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