I think these are the wrong solutions. What they're trying to do is to desperately hold on to doing "business as usual". Just now with a CYA fig leaf, and do I detect a hint of possibly a dash of malicious compliance?

What the EU actually wants to accomplish is to set a standard where people do business in a different (safer/higher quality/more ethical) way[1]; which many believe is both better for consumers and for business.

I wouldn't be surprised if a next round of regulations were to explicitly target (actual or perceived) malicious compliance.

My recommendation would be to find other ways of achieving your technical/advertising objectives that minimize the touching of peoples PII.

[1] This is not unusual, the EU originated as the European Economic [Community/Union], and the regulating of safety, quality and ethics standards between businesses and trading countries has been in their bailiwick for a long time (as behooves a trade treaty organization). Not all kinds of regulation are bad for commerce. This kind promotes fair competition and interoperability, while preventing races to the bottom and tragedies of the commons.