The program in and of itself is not one that we can readily point a finger at and say with complete conviction that it *is* spyware. After all, the spy part of spyware implies that it is doing this without you, the end user of the machine, knowing it.
It will only be usable on very specific hardware, for one thing, and you, the end user, can turn it off any time that you want. Its intentions are clear, as well as its usability.
Do you consider that your browser storing your history also spyware? As long as your session is open, unless you manually clear your history, it's all there - and not just a few days of it, either.
If you're gonna refer to Recall as spyware, then you might as well call every single browser out there spyware as well.