Predatory usually implies that you're being lured in to buy something, but the game has no microtransactions. At its worst the mobile version (which is free) has the option to watch an ad to get 1 revive per run. Don't watch the ad? The game is the same as the console/PC version.

I think the lights, sounds, slaughtering massive hordes of enemies with overwhelming damage, and constant dopamine rush from them could certainly be predatory in nature if they were used to bait you into buying microtransactions, but that's not the case here. I see where they're coming from, but I can't necessarily agree.