I may be missing something, but I don't see how this clearly precludes that behavior.

Which descriptor do you think is unambiguously violated by making it easier to provide consent than withhold it? To my eyes, both 'freely' and 'informed' are plausibly upheld.

It would be very straightforward to specify that consent and withholding must be equally accessible in the interface, instead of splitting hairs about definitions of "freely given". This is what people refer to when they say the law is poorly written