Early on, it's not personally identifiable. No doubt there can be a lot of folks visiting the site only 10 times and never again.
But as someone continues to visit, they begin to narrow down who they are to "You're that guy that comes in here every day with a yellow hat". They may not "know" who you are but, they "know" who you are.
Eventually, there may be that one person that has the highest hit rate, who always stands out.
Yes but you have absolutely nothing at all to associate that back to a person. Where are you going to find the data "personal information of some kind of the people who visit your site a lot?" You're not collecting it.
They could stop incrementing once they get to 10 (or something that's high but common enough to be shared by 1,000s of people).
Using personal data to assign a cohort counts as using personal data. Duh. The approach described in the article doesn't use any personal data, though?
Quoting the European commission:
"Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data."
I'd hazard a guess that it's the second part under which the EC might find this to be within scope.
That doesn't mean you can't use it at all. It just places strong restrictions on what purpodes you can use it for. The important point is just that those restrictions are the same under GDPR for all of these technologies. It doesn't matter how you uniquely identify users, what matters is what you do with that information.
You may be able to look at the headers and see that a certain user made the most requests that day. That still tells you nothing about their identity.
What the technique may fall foul of, though, are cookie laws.
Edit: Huh, I stand corrected I don't know if this would count as personal data.
The post says that they don't combine datapoints because that would negate privacy.
Using it for user analytics, which is neither required to run the service, nor in the users interest, nor reasonably expected by the user, is almost definitly illegitimate use.