Seems so. Checked the sources and there's no upload/download. And testing it I can confirm the network tab in the dev tools is silent. Everything work local side. Probably with some additional work this could be converted to a PWA (Progressive Web App) and work completely offline.
I would add Outer Wilds to the list.
You can really only play it once in a lifetime but I think it's the best video game experiences available.
Honorable mention for Tunic and Cocoon for the same reason