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IP is not a user-entered data and cannot be freely selected, unlike email addresses.

> the fact that your email isn't yourname@mailprovider.com doesn't make it any less identifiable.

The only official guidelines about email I could find are in here [1]. It does not say all email addresses are PII. It just says "name.surname@company.com" type addresses are PII and "info@company.com" type addresses are NOT PII. So even "yourname@mailprovider.com" may be non-PII.

> someone can use it to identify additional information about you such as if you are subscribed to a specific service or not.

Thats not enough. The service need to have PII. That is, if none of the services has PII, the email address is not PII.

> you can't ask users to make a throwaway email account

Throwaway is not needed. At best an individual need 2 email accounts. One address for the services where he is identified (eg bank website) and one address for where he is not (eg random forum).

So this is not an onerous condition at all. If thats the case you are making.

> If the website asks for an email address that is PII under the GDPR.

This is not a (official) citation.

[1] https://ec.europa.eu/info/law/law-topic/data-protection/refo...




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