The company is based in an EU, EEA, EFTA, or DCFTA member country.
So Moldova, Ukraine and Georgia included, but not Turkey (only tariff union), neither are Belarus, Russia, UK, and much of the Balkans. Iceland is included, Greenland isn't, Faroer should be via Iceland, same goes for Monaco via France, San Marino via Italy etc. Switzerland in particular is included because EFTA.
The problem is: Data is code, and code is data. An algorithm to compute prime numbers is equivalent to a list of prime numbers, (also, not relevant to this discussion, homoiconicity and interpretation). Yet we still want to make a distinction.
Is a PAQ-compressed copy of the Hitchhiker's guide code? Technically, yes, practically, no, because the code is just a fancy representation of data (PAQ is basically an exercise in finding algorithms that produce particular data to save space). Is a sorting algorithm code? Most definitely, it can't even spit out data without being given an equally-sized amount of data. On that scale, from code to code representing data, AI models are at least 3/4th towards code representing data.
As such I'd say that AI models are data in the same sense that holograms (these ones) are photographs. Do they represent a particular image? No, but they represent a related, indexable, set of images. What they definitely aren't is rendering pipelines. Or, and that's a whole another possible line of argument: Requiring Turing-complete interpretation.