And going the quotations in TFA, it seems the FSF's thinking about this is clear and nuanced, as usual:
> [T]he FSF makes a distinction between non-free and unethical in this case:
> > It may be that some nonfree ML have valid moral reasons for not releasing training data, such as personal medical data. In that case, we would describe the application as a whole as nonfree. But using it could be ethically excusable if it helps you do a specialized job that is vital for society, such as diagnosing disease or injury.
If they end up needing new terminology to describe this case, I'm sure they will devise some-- and it will be more explicit than a moniker like 'shared source'.