Unless they have a non-IP based communication system, then they'll fall afoul of the same thing all online analytics services do - they'll be collecting, at least ephemerally, personal data under the EU definition.
It is my understanding that if you do not log the IPs that connect, then you are not collecting personal data.
Last year, a German court fined a website for using Google Fonts as it was providing the IP address to Google without authorization and without a legitimate reason for doing so.
It seems likely that the same reasoning will apply here.