https://www.europarl.europa.eu/news/de/press-room/20231205IP...
But I have no real basis for that, I would assume that based kickstarter and co also getting money from consumers without having to abide by any consumer rights.
I assume that the option of donating while keeping the software available free of charge would fall under the same category as getting gifts from strangers
Contrary getting displaying ads directly in the app would fall under commercial activity because you force the user of the app to give you money(via an ad provider)