I... do not think so? Yes, creating a commercial github action to apply terraform would, but any non-commercial and/or non-distributed one should be fine, no?
Using GitHub Actions to deploy your Terraform code (you becoming the third party) is competitive with HashiCorp's products. There is no delineation about commercialization.
HashiCorp probably won't come after you, but to me it shows this wasn't really thought through or it's maliciously ambiguous.