"If a business collects and processes IP addresses, but has no legal means of linking those IP addresses to the identities of the relevant users, then those IP addresses are unlikely to be personal data. However, businesses should note that if they have sufficient information to link an IP address to a particular individual (e.g., through login details, cookies, or any other information or technology) then that IP address is personal data, and is subject to the full protections of EU data protection law."
"If a business collects and processes IP addresses, but has no legal means of linking those IP addresses to the identities of the relevant users, then those IP addresses are unlikely to be personal data. However, businesses should note that if they have sufficient information to link an IP address to a particular individual (e.g., through login details, cookies, or any other information or technology) then that IP address is personal data, and is subject to the full protections of EU data protection law."
https://www.whitecase.com/publications/alert/court-confirms-...