I don't buy that that allows you to send random requests to parties that you have no way of knowing the requester has a relationship with. That is an unreasonable burden to place on the recipient of such a request. Essentially you will be sending them on a wild goose chase which is against the
intent of the law, which is to give people control over their data, not for people to harass random companies, even more so to do this in an automated way.
You can of course go and approach this from a legalistic point of view but that's usually not how things work in the EU, if you are going to split legal hairs to see how you might be able to get away with something then you will be in for a surprise.
But don't take my word for it, feel free to build and launch the service and we'll see if it flies. For $40 I'll pass :)