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For the typical user (who gets an e-reader to read books and not as an end in itself), depending on where in the world they're located, one device is likely going to be about 30% more expensive than the other, so regardless of whatever little differences exist between the two it's probably best to choose on price, especially as these things are already not great value for money (my guess is the BOM adds up to less than $10 excluding the E Ink screen).
For those who like to customize things, Tolino is arguably better, as it can be readily made to run just about any Android application, which gives access to the whole "ecosystem." For this reason, there also isn't much point, in my opinion, in debating software differences between the two: if you don't like the stock reader application on the Tolino, you can just use any of the third-party ePub viewers out there instead (Librera is my favorite as of now, although I don't know how it handles E Ink screens; CoolReader is always a safe bet).
For people who are privacy-conscious, the EU, and Germany in particular, have stronger privacy protections, so Tolino is less likely to attempt some shenanigans with regard to this (not that I'm aware of any issues with Kobo in this aspect).
Comparing the Tolino Shine 3 and Kobo Clara HD specifically, it also seems (although I haven't tried it) that the Tolino could be made to run pure Linux and Kobo software on it, while it would be much more difficult, if not downright impossible, to run Android on the Clara HD.
On the other hand, pure Linux should be faster than Android and on top of that the Clara HD has a marginally better CPU but I'm not sure if this is noticeable in actual usage.
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