Why it has to include PII by definition? I'd say DNF Counting (https://github.com/fedora-infra/mirrors-countme) should be considered "telemetry", yet it doesn't seem to collect any personal data, at least by what I understand telemetry and personal data to mean.
I'm guessing that you'd either have to be able to argue that DNF Counting isn't telemetry, or that it contains PII, but I don't see how you could do either.