Good strategy.
Even if donation-ware would be considered nc by most, one might want to change business model in the future to premium versions. And with that there would be no discussion about how non c the project would be.
With donation there is at least an ambigous area. It would be easier, if the money aspect would be more fleshed out. Because strictly, even if you do not make profit, your intent was to do so. But intent is hard to prove, so actions have to spell out the intent. (Otherwise you could just claim, ohhh, we never intended to make a profit by selling this hot new rogue like with addicting game mechanics and stunning nc art.) And if you do look at actions alone, giving away a thing for free does not look very profit orientated, or in other words, commercial. Accepting donations does not change this, as there is no obligation.