This is 100% commercial use.
That's one of the least problems with the FBAlpha licensing, to be honest.
FBAlpha has GPL code in it. Only the original authors can relicense it, and until they do, that GPL code can't be combined to create a derivative work unless that code is with a GPL-compatible license.
The best hope of salvaging it is by abusing the clause that says "Due to the use of MAME code in FB Alpha, FB Alpha is also subject to the terms of the MAME license." (which lets you argue that the whole thing is GPL), but that doesn't solve the issue of the code with limitations on commercial use that was not contributed by the original author (like Dave and FinalBurn).
Put simply, the only license that FBAlpha could legally be distributed under would be the GPL, but the GPL doesn't work given some of the code in there. Basically, the whole project is a mess.
The restrictions on commercial use simply don't fly with GPL code. Given the mismatch of licenses, the only real option to make this legal would be to either re-write or contact the authors to relicense the SP0256, i8x41, arm7, mcs51, NMOS 6502 illegal opcodes, 65sc02, 2a03, and other drivers. In theory, one could just remove all the MAME and GPL parts, but then all the "non-commercial" parts would still apply.
It's a real mess, and licensing has been neglected for some time. I attempted to post an issue about it on GitHub, but Barry just turned the issues off completely shortly after I did.