No data dump and low daily-cap API: Can it be called Open Data?

Question

Imagine a service that claims all of its data is Open Data, but:

• Data dumps are not available
• Data is huge
• The only way to get data is the API, which is limited to 50 requests per day (0.001% of total)
• Using several API keys for the same project/endeavour is forbidden and frowned upon

Seeing it branded as Open Data (BY-NC-SA), many people are contributing new items, at a faster rate than 50 per day.

Question: Can this be called Open Data?
Or does the idea of Open Data somehow require that it is possible to download the whole data without resorting to subterfuges?

Answer 1

To quote from the Open Definition v2.0:

1.2 Access

The work shall be available as a whole and at no more than a reasonable one-time reproduction cost, preferably downloadable via the Internet without charge. […]

So no, what you describe is not Open Data according to the Open Definition.