I strongly disagree. It is not opaque enough.
You do not have the freedoms to:
Study and understand: A model's behavior heavily relies on its training data. Without it, fully grasping why the model makes specific predictions is difficult (nearly impossible for sophisticated models).
Improve and adapt: Effective improvements often require retraining with modified or additional data. Without the original training data, replicating or enhancing the model's capabilities is challenging.