The section you mentioned does not say anything about having counters for labels. It only mentions that they record "[t]he times of the first and most recent instances of queries for each query label".
Well, the counters aren't data collected, they are data derived from the data they do collect. The privacy policy covers collection.
EDIT: I see they went out of their way to say "this is the complete list of everything we count" and they did not include counters by label, so I see your point!
EDIT: I see they went out of their way to say "this is the complete list of everything we count" and they did not include counters by label, so I see your point!