Is the connectivity layer considered: Is the 3rd party "proxy" handler uploading the information using an Apple ID? Does Apple record, store IP information? It seems to me that by using this system you volunteer to send data to Apple constantly which may not reveal your GPS location but will reveal your network location.
I'm happy to see someone trying to innovate in this space. I still wonder if it is okay for journalists and risk affected users to use this or if they should be advised to avoid it.
this is discussed here in the comments extensively. The best answer is that they block Germany because they expect if they complied by only blocking certain books they would have to deal with many more requests in the future. They also decided to take this chance to make a statement to encourage a public debate.
I'm happy to see someone trying to innovate in this space. I still wonder if it is okay for journalists and risk affected users to use this or if they should be advised to avoid it.