They never ask for "robots.txt", and then they download your entire site every month, for starters. Further, they lie about who they are. They send a User Agent string that doesn't reflect that it's a bot doing the downloading. The User Agent string claims to be Internet Explorer on a Windows box, yet p0f recognizes the requests as from a Linux TCP/IP stack.

Trolling for "intellectual property" infringement for third parties also seems like a scummy line of work to me. It's in Cyveillance interest to find infringements, so there's no economic reason for them to get such findings correct.

So, I conclude they're a bad actor.