It's a data structure, except it doesn't describe how data is actually stored, only how its elements interact, so it's a data structure that doesn't actually structure data. If you are the kind of person that considers stuff like MVVM and Clean Architecture to be data structures, then I suppose it would be consistent. Most people don't.
It does store data so it is a data structure. Every implementation is meant to store data and the whole point is to have more memory locality so how it stores data is actually crucial.