Yes, you are right that there is another part of the definition about large scale, regular and "systematic monitoring" of individuals. Apologies for not including that in the answer above.
Quoting from WP 243 Annex provided by the EU:
"The notion of regular and systematic monitoring of data subjects is not defined in the GDPR, but clearly includes all forms of tracking and profiling on the internet, including for the purposes of behavioural advertising. However, the notion of monitoring is not restricted to the online environment."
Quoting from WP 243 Annex provided by the EU:
"The notion of regular and systematic monitoring of data subjects is not defined in the GDPR, but clearly includes all forms of tracking and profiling on the internet, including for the purposes of behavioural advertising. However, the notion of monitoring is not restricted to the online environment."
The link is here
https://ec.europa.eu/information_society/newsroom/image/docu...
We anonymize and aggregate all data so can't track or profile any users, or do such monitoring offline.