Legitimate Interest

JUN GROUP LEGITIMATE INTEREST ASSESSEMENTS

TCF Purposes 2, 7, 9, 10

TCF Special Purposes 1, 2, 3

TCF PURPOSE 2: 

BASIC ADS SERVING AND FREQUENCY CAPPING

 

Executive Summary

This Legitimate Interest Assessment (LIA) evaluates the lawful basis for processing personal data under TCF Purpose 2 (Select basic ads) using legitimate interest pursuant to GDPR Article 6(1)(f). Our assessment concludes that legitimate interest is appropriate for basic ad serving and frequency capping using minimal technical identifiers.

 

  1. Purpose Test – Identification of Legitimate Interest

Business Interest

Our legitimate interest is to deliver relevant advertising content and prevent ad fatigue through basic ad serving and frequency capping mechanisms. This serves multiple stakeholders:

  • Commercial viability: Enables sustainable digital advertising ecosystem supporting free online content
  • User experience: Prevents excessive ad repetition that degrades user experience
  • Advertiser value: Ensures efficient ad spend through controlled exposure frequency
  • Publisher revenue: Maintains advertising revenue streams that fund free digital content

 

Legal Assessment

This interest is:

  • Real and present: Directly tied to our core business operations as an ad tech vendor
  • Specific: Limited to basic ad delivery and frequency management
  • Lawful: Aligned with legitimate commercial activities in digital advertising

 

  1. Necessity Test – Proportionality Assessment

Processing Activities

Data Processed:

  • Mobile device identifiers (IDFA, GAID)
  • IP addresses
  • Internal unique identifiers (non-public)

 

Processing Purposes:

  • Ad selection and delivery
  • Frequency capping to prevent overexposure
  • Basic performance measurement

 

Necessity Analysis

The processing is strictly necessary because:

  • Technical Necessity:
    • Device IDs enable ad delivery to specific devices without requiring personal identification
    • IP addresses facilitate technical ad serving infrastructure
    • Internal identifiers support frequency capping across sessions
  • No Less Intrusive Alternatives:
    • Consent would create friction reducing advertising effectiveness and publisher revenue
    • Anonymous processing insufficient for frequency capping functionality
    • Alternative identifiers would require more invasive data collection
  • Proportionate Scope:
    • Data collection limited to technical identifiers only
    • No behavioral profiling or detailed user tracking
    • Processing restricted to immediate ad serving needs

 

  1. Balancing Test – Fundamental Rights Assessment

 

Data Subject Impact Analysis

  • Low Privacy Impact:
    • Technical data only: No sensitive personal information processed
    • Limited inference potential: Basic identifiers don’t reveal personal characteristics; limited to device-specific data
    • Temporary processing: Data used for immediate ad serving, not long-term profiling
    • No behavioral tracking: Purpose 2 excludes personalization and audience insights
  • Reasonable Expectations:
    • Users expect ads on free, ad-supported apps and websites
    • Frequency capping improves rather than degrades user experience
    • Processing aligns with standard digital advertising practices
    • Transparent disclosure through TCF framework

 

Rights and Freedoms Assessment

  • Minimal Interference:
    • Privacy: Low-risk technical identifiers with limited personal data exposure
    • Data protection: Robust security measures and data minimization practices
    • Freedom of expression: Supports free digital content and participation in and with apps through advertising revenue
  • Safeguards in Place:
    • Data minimization: Only essential identifiers collected; all are tied to users’ device rather than the individual person
    • Purpose limitation: Strictly limited to basic ad serving
    • Transparency: Clear disclosure through TCF consent management
    • User control: Opt-out mechanisms available
    • Security: Industry-standard data protection measures

 

Balancing Conclusion

Our legitimate commercial interests in basic ad serving do not override data subjects’ fundamental rights because:

  1. Minimal data processing with low privacy risk
  2. Clear user benefit through improved ad experience
  3. Proportionate measures with appropriate safeguards
  4. Transparent processing with user control options
  5. Essential functionality for sustainable digital ecosystem

 

  1. Additional Safeguards

 

Technical Measures

  • Data encryption in transit and at rest
  • Access controls and audit logging
  • Regular security assessments
  • Data retention limits aligned with business necessity

 

Organizational Measures

  • Privacy by design implementation
  • Regular Legitimate Interest Assessment reviews and updates
  • Staff training on data protection
  • Incident response procedures

 

User Rights

  • Clear privacy notice disclosure
  • Easy opt-out mechanisms
  • Data subject request handling procedures
  • Regular consent management platform updates

 

  1. Conclusion

 

Based on this three-part assessment, legitimate interest is the appropriate lawful basis for TCF Purpose 2 processing. The assessment demonstrates:

  • Valid legitimate interest in basic ad serving and frequency capping
  • Necessary processing of minimal personal data with no less intrusive alternatives
  • Balanced approach that respects data subject rights 

 

This LIA will be reviewed at least annually or when processing activities change materially.

 

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TCF PURPOSE 7:

MEASURE ADVERTISING PERFORMANCE

 

Executive Summary

This Legitimate Interest Assessment (LIA) evaluates the lawful basis for processing personal data under TCF Purpose 7 (Measure ad performance) using legitimate interest pursuant to GDPR Article 6(1)(f). Our assessment concludes that legitimate interest is appropriate for measurement of ad performance using minimal technical identifiers.

 

  1. Purpose Test – Identification of Legitimate Interest

Business Interest

Our legitimate interest is to measure the performance of the advertisements we serve. This serves multiple stakeholders:

  • Commercial viability: Enables sustainable digital advertising ecosystem supporting free online content
  • Advertiser value: Ensures efficient ad spend through measurement of performance
  • Publisher revenue: Maintains advertising revenue streams that fund free digital content and serves as proof of performance

 

Legal Assessment

This interest is:

  • Real and present: Directly tied to our core business operations as an ad tech vendor
  • Specific: Limited to measurement of ad performance
  • Lawful: Aligned with legitimate commercial activities in digital advertising

 

  1. Necessity Test – Proportionality Assessment

Processing Activities

Data Processed:

  • Mobile device identifiers (IDFA, GAID)
  • IP addresses
  • Internal unique identifiers (non-public)

 

Processing Purposes:

  • Basic performance measurement

 

Necessity Analysis

The processing is strictly necessary because:

  • Technical Necessity:
    • Device IDs enable measurement of unique ad impressions without requiring personal identification
    • IP addresses facilitate technical ad serving infrastructure
    • Internal identifiers support measurement across sessions
  • No Less Intrusive Alternatives:
    • Consent would create friction reducing advertising effectiveness and publisher revenue
    • Anonymous processing insufficient for adequate measurement
    • Alternative identifiers would require more invasive data collection
  • Proportionate Scope:
    • Data collection limited to technical identifiers only
    • No behavioral profiling or detailed user tracking
    • Processing restricted to immediate ad serving needs

 

  1. Balancing Test – Fundamental Rights Assessment

 

Data Subject Impact Analysis

  • Low Privacy Impact:
    • Technical data only: No sensitive personal information processed
    • Limited inference potential: Basic identifiers don’t reveal personal characteristics; limited to device-specific data
    • Temporary processing: Data used for immediate ad serving, not long-term profiling
    • No behavioral tracking: Purpose 7 excludes personalization and audience insights
  • Reasonable Expectations:
    • Users expect ads on free, ad-supported apps and websites
    • Basic measurement improves rather than degrades user experience
    • Processing aligns with standard digital advertising practices
    • Transparent disclosure through TCF framework

 

Rights and Freedoms Assessment

  • Minimal Interference:
    • Privacy: Low-risk technical identifiers with limited personal data exposure
    • Data protection: Robust security measures and data minimization practices
    • Freedom of expression: Supports free digital content and participation in and with apps through advertising revenue
  • Safeguards in Place:
    • Data minimization: Only essential identifiers collected; all are tied to users’ device rather than the individual person
    • Purpose limitation: Strictly limited to measurement of ad performance
    • Transparency: Clear disclosure through TCF consent management
    • User control: Opt-out mechanisms available
    • Security: Industry-standard data protection measures

 

Balancing Conclusion

Our legitimate commercial interests in measurement of ad performance do not override data subjects’ fundamental rights because:

  1. Minimal data processing with low privacy risk
  2. Clear user benefit through improved ad experience
  3. Proportionate measures with appropriate safeguards
  4. Transparent processing with user control options
  5. Essential functionality for sustainable digital ecosystem

 

  1. Additional Safeguards

 

Technical Measures

  • Data encryption in transit and at rest
  • Access controls and audit logging
  • Regular security assessments
  • Data retention limits aligned with business necessity

 

Organizational Measures

  • Privacy by design implementation
  • Regular Legitimate Interest Assessment reviews and updates
  • Staff training on data protection
  • Incident response procedures

 

User Rights

  • Clear privacy notice disclosure
  • Easy opt-out mechanisms
  • Data subject request handling procedures
  • Regular consent management platform updates

 

  1. Conclusion

 

Based on this three-part assessment, legitimate interest is the appropriate lawful basis for TCF Purpose 7 processing. The assessment demonstrates:

  • Valid legitimate interest in measurement of ad performance
  • Necessary processing of minimal personal data with no less intrusive alternatives
  • Balanced approach that respects data subject rights 

 

This LIA will be reviewed at least annually or when processing activities change materially.

 

—————————————

TCF PURPOSE 9: 

UNDERSTAND AUDIENCES THROUGH STATISTICS

 

Executive Summary

This Legitimate Interest Assessment (LIA) evaluates the lawful basis for processing personal data under TCF Purpose 9 (Understanding audiences through statistics) using legitimate interest pursuant to GDPR Article 6(1)(f). Our assessment concludes that legitimate interest is appropriate for understanding audiences through statistics using minimal technical identifiers.

 

  1. Purpose Test – Identification of Legitimate Interest

Business Interest

Our legitimate interest is to understand through statistics the audiences that our advertisements reach. This serves multiple stakeholders:

  • Commercial viability: Enables sustainable digital advertising ecosystem supporting free online content
  • Consumer value: Improves overall ad quality leading to a better user experience
  • Advertiser value: Ensures efficient ad spend through statistical analysis of audiences
  • Publisher revenue: Maintains advertising revenue streams that fund free digital content

 

Legal Assessment

This interest is:

  • Real and present: Directly tied to our core business operations as an ad tech vendor
  • Specific: Limited to statistical analysis to further understanding of our advertising audience
  • Lawful: Aligned with legitimate commercial activities in digital advertising

 

  1. Necessity Test – Proportionality Assessment

Processing Activities

Data Processed:

  • Mobile device identifiers (IDFA, GAID)
  • IP addresses
  • Internal unique identifiers (non-public)

 

Processing Purposes:

  • Statistical analysis for understanding of audiences without the development of profiles.

 

Necessity Analysis

The processing is strictly necessary because:

  • Technical Necessity:
    • Device IDs enable analysis of individual device users without requiring personal identification
    • IP addresses facilitate technical ad serving infrastructure
    • Internal identifiers support audience analysis across sessions
  • No Less Intrusive Alternatives:
    • Consent would create friction reducing advertising effectiveness and publisher revenue
    • Anonymous processing insufficient for adequate statistical audience analysis
    • Alternative identifiers would require more invasive data collection
  • Proportionate Scope:
    • Data collection limited to technical identifiers only
    • No behavioral profiling or detailed user tracking
    • Processing restricted to immediate ad serving needs

 

  1. Balancing Test – Fundamental Rights Assessment

 

Data Subject Impact Analysis

  • Low Privacy Impact:
    • Technical data only: No sensitive personal information processed
    • Limited inference potential: Basic identifiers don’t reveal personal characteristics; limited to device-specific data
    • No behavioral tracking: Purpose 9 excludes profile development
  • Reasonable Expectations:
    • Users expect ads on free, ad-supported apps and websites
    • Basic audience analysis improves rather than degrades user experience
    • Processing aligns with standard digital advertising practices
    • Transparent disclosure through TCF framework

 

Rights and Freedoms Assessment

  • Minimal Interference:
    • Privacy: Low-risk technical identifiers with limited personal data exposure
    • Data protection: Robust security measures and data minimization practices
    • Freedom of expression: Supports free digital content and participation in and with apps through advertising revenue
  • Safeguards in Place:
    • Data minimization: Only essential identifiers collected; all are tied to users’ device rather than the individual person
    • Purpose limitation: Strictly limited to statistical audience analysis
    • Transparency: Clear disclosure through TCF consent management
    • User control: Opt-out mechanisms available
    • Security: Industry-standard data protection measures

 

Balancing Conclusion

Our legitimate commercial interests in statistical audience analysis do not override data subjects’ fundamental rights because:

  1. Minimal data processing with low privacy risk
  2. Clear user benefit through improved ad experience
  3. Proportionate measures with appropriate safeguards
  4. Transparent processing with user control options
  5. Essential functionality for sustainable digital ecosystem

 

  1. Additional Safeguards

 

Technical Measures

  • Data encryption in transit and at rest
  • Access controls and audit logging
  • Regular security assessments
  • Data retention limits aligned with business necessity

 

Organizational Measures

  • Privacy by design implementation
  • Regular Legitimate Interest Assessment reviews and updates
  • Staff training on data protection
  • Incident response procedures

 

User Rights

  • Clear privacy notice disclosure
  • Easy opt-out mechanisms
  • Data subject request handling procedures
  • Regular consent management platform updates

 

  1. Conclusion

 

Based on this three-part assessment, legitimate interest is the appropriate lawful basis for TCF Purpose 9 processing. The assessment demonstrates:

  • Valid legitimate interest in understanding of audiences through statistical analysis
  • Necessary processing of minimal personal data with no less intrusive alternatives
  • Balanced approach that respects data subject rights 

 

This LIA will be reviewed at least annually or when processing activities change materially.

 

—————————————

 

TCF PURPOSE 10: 

DEVELOP AND IMPROVE SERVICES

 

Executive Summary

This Legitimate Interest Assessment (LIA) evaluates the lawful basis for processing personal data under TCF Purpose 10 (Develop and improve services) using legitimate interest pursuant to GDPR Article 6(1)(f). Our assessment concludes that legitimate interest is appropriate for the development and improvement of our services using minimal technical identifiers.

 

  1. Purpose Test – Identification of Legitimate Interest

Business Interest

Our legitimate interest is to continue development and improvement of our adtech services. This serves multiple stakeholders:

  • Commercial viability: Enables sustainable digital advertising ecosystem supporting free online content
  • Consumer value: Improves overall ad quality and delivery of ads leading to a better user experience
  • Advertiser value: Ensures efficient ad spend through improved ad delivery and development of new services
  • Publisher revenue: Maintains advertising revenue streams that fund free digital content and enhances publisher experience through service improvements

 

Legal Assessment

This interest is:

  • Real and present: Directly tied to our core business operations as an ad tech vendor
  • Specific: Limited to improvement and development of our services
  • Lawful: Aligned with legitimate commercial activities in digital advertising

 

  1. Necessity Test – Proportionality Assessment

Processing Activities

Data Processed:

  • Mobile device identifiers (IDFA, GAID)
  • IP addresses
  • Internal unique identifiers (non-public)

 

Processing Purposes:

  • Development and improvement of our adtech services, without building user profiles
  • Review of performance for different ad formats and delivery mechanisms

 

Necessity Analysis

The processing is strictly necessary because:

  • Technical Necessity:
    • Device IDs enable analysis of individual device users without requiring personal identification
    • IP addresses facilitate technical ad serving infrastructure
    • Internal identifiers support review of service performance across sessions
  • No Less Intrusive Alternatives:
    • Consent would create friction reducing advertising effectiveness and publisher revenue
    • Anonymous processing insufficient for adequate development and improvement of services
    • Alternative identifiers would require more invasive data collection
  • Proportionate Scope:
    • Data collection limited to technical identifiers only
    • No behavioral profiling or detailed user tracking
    • Processing restricted to general service developments and improvements, no user-specific processing

 

  1. Balancing Test – Fundamental Rights Assessment

 

Data Subject Impact Analysis

  • Low Privacy Impact:
    • Technical data only: No sensitive personal information processed
    • Limited inference potential: Basic identifiers don’t reveal personal characteristics; limited to device-specific data
    • No behavioral tracking: Purpose 10 excludes profile development
  • Reasonable Expectations:
    • Users expect ads on free, ad-supported apps and websites
    • Development and improvement so services enhances rather than degrades user experience
    • Processing aligns with standard digital advertising practices
    • Transparent disclosure through TCF framework

 

Rights and Freedoms Assessment

  • Minimal Interference:
    • Privacy: Low-risk technical identifiers with limited personal data exposure
    • Data protection: Robust security measures and data minimization practices
    • Freedom of expression: Supports free digital content and participation in and with apps through advertising revenue
  • Safeguards in Place:
    • Data minimization: Only essential identifiers collected; all are tied to users’ device rather than the individual person
    • Purpose limitation: Strictly limited to development and improvement of services
    • Transparency: Clear disclosure through TCF consent management
    • User control: Opt-out mechanisms available
    • Security: Industry-standard data protection measures

 

Balancing Conclusion

Our legitimate commercial interests in developing and improving our services do not override data subjects’ fundamental rights because:

  1. Minimal data processing with low privacy risk
  2. Clear user benefit through improved ad experience
  3. Proportionate measures with appropriate safeguards
  4. Transparent processing with user control options
  5. Essential functionality for sustainable digital ecosystem

 

  1. Additional Safeguards

 

Technical Measures

  • Data encryption in transit and at rest
  • Access controls and audit logging
  • Regular security assessments
  • Data retention limits aligned with business necessity

 

Organizational Measures

  • Privacy by design implementation
  • Regular Legitimate Interest Assessment reviews and updates
  • Staff training on data protection
  • Incident response procedures

 

User Rights

  • Clear privacy notice disclosure
  • Easy opt-out mechanisms
  • Data subject request handling procedures
  • Regular consent management platform updates

 

  1. Conclusion

 

Based on this three-part assessment, legitimate interest is the appropriate lawful basis for TCF Purpose 10 processing. The assessment demonstrates:

  • Valid legitimate interest in development and improvement of services
  • Necessary processing of minimal personal data with no less intrusive alternatives
  • Balanced approach that respects data subject rights 

 

This LIA will be reviewed at least annually or when processing activities change materially.

 

TCF SPECIAL PURPOSE 1: 

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TCF SPECIAL PURPOSE 2: 

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TCF SPECIAL PURPOSE 3: 

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