Legitimate Interest Assessments

Summary

Advertising presented to you on this service can be based on limited data, such as the website or app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you).

Purpose Test

Advertisers use Smartology to deliver semantically relevant adverts to users solely based on the context of the pages the users are currently consuming and not by using any personal information about, or profiles of, the users themselves. We work with a discrete number of publishers, on both their websites and apps, to deliver such contextually matched adverts.

When a user consumes an article, our systems perform a search for the advert with the highest semantic match between the content of that advert and the content of the article being consumed. We also apply proprietary brand safety technology to prevent an advertiser’s content being served next to publisher content on crime, terrorism, disasters etc.

Delivering contextually relevant adverts to users has the benefit of giving those users a more relevant and useful advertising experience which leads to higher engagement with those adverts.

Necessity Test

Our systems receive many signals in a bid request but to select the most semantically relevant advertiser item to the content being viewed, most of the data from this request is ignored. For the purpose of selecting the best advert, Smartology processes the following:

• The publisher and URL of the page the user is consuming (used to semantically match that article’s content against advertiser content using proprietary Natural Language Processing algorithms)
• The country in which the user is located (used to enable an advertiser to target their campaigns at specific countries)
• The id of the publisher app being used to access the content (used to enable an advertiser to target a specific publisher app)
• The device type of the user (used to enable an advertiser to target their campaigns specifically at mobile devices)

Balancing Test

We don’t have a direct relationship with the individual and only serve adverts that are relevant to the article that the individual is viewing at that moment in time. We consider this to be non-intrusive as no historical or personally identifiable information is used in this process. We consider that selecting the most relevant advert using only the content being viewed and the country that it's being viewed in is processing that the user would reasonably expect to happen and allows us to meet regulatory requirements and observe GDPR. It also has the benefit of giving the user a more useful and pertinent advertising experience without using any private or sensitive information. Children are excluded from advert targeting. We honour the signals in the Transparency and Consent framework thus giving the ability for individuals to opt-out of our processing using a Legitimate Interest objection.

Summary

Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns.

Purpose Test

Advertisers use Smartology to deliver semantically relevant adverts to users solely based on the context of the pages the users are currently consuming and not by using any personal information about, or profiles of, the users themselves.

We measure adverts in the following ways:

• We record when an advert is served to a user. This enables our systems to accurately spend the budgets our advertisers have allocated to their campaigns and to verify our numbers against those billed for by the advertising exchange
• We record the actions of clicking on an advert or scrolling through the content of an advert. This data is not linked to the user, but aggregated with all activity from all users to guarantee anonymity

The above measurements allow us to report to the advertisers on the performance and effectiveness of their adverts and to make adjustments to ensure that their budgets are being spent as effectively as possible.

Necessity Test

To enable our systems to measure when an advert is served, the data we record, and why we need to record it, consists of:

• Timestamp of when the advert was served (used for measurement reporting and fraud detection)
• The publisher and URL of the page the user was consuming (used for measurement reporting, to demonstrate the contextual similarity)
• Content of the advert served (used for measurement reporting)
• IP address (used solely for fraud detection purposes - See Special Purpose 1)
• A relevance score for the advert in the context of the page the advert appears in (used for optimising campaign delivery, engagement and for spending the budget effectively)
• The price that was bid for the advert and the price that was paid (used to manage budget spend)
• Internal system identifiers (used by the programmatic bidding process)

To enable our systems to measure when an advert was clicked or scrolled, the data that we record, and why we need to record it, consists of:

• Timestamp of when the event occurred (used for measurement reporting)
• Destination URL of the advert landing page (used for measurement reporting)
• Page the user was consuming (used for measurement reporting)
• IP address (used solely for fraud detection purposes)
• Internal system identifiers (used by the programmatic bidding process)

We do not link the above data to an individual for the purpose of building a profile, targeting adverts, making decisions on which adverts to serve or for sharing with any third parties.

Balancing Test

We don’t have a direct relationship with the individual and only measure adverts to ensure that advertising campaigns are run correctly and in the most effective manner. We consider that the data that we use and record for the purpose of advert measurement does not impact the user’s privacy and we consider measurement to be processing that the user could reasonably expect to happen. We honour the signals in the Transparency and Consent framework thus giving the ability for individuals to opt-out of this processing using a Legitimate Interest objection.

Summary

Your data can be used to monitor for and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems you, the publisher or the advertiser may encounter in the delivery of content and ads and in your interaction with them.

Purpose Test

Advertisers use Smartology to deliver semantically relevant adverts to users solely based on the context of the pages the users are currently consuming and not by using any personal information about, or profiles of, the users themselves.

For the purpose of fraud detection, we process and store a number of parameters that allow us to perform analyses of the interactions of the viewers of our adverts in order to detect and exclude automated and fraudulent actors such as bots and botnets. These parameters are not used to profile any individual and are solely used for fraud detection. The advertiser benefits from this processing as we ensure they only pay for adverts that are viewed by real users. We benefit by excluding fraudulent actors from being served adverts by our systems. Finally, excluding bad actors will in general create a more favourable view of the programmatic advertising ecosystem.

Necessity Test

In order to be able to detect and exclude fraudulent actors from viewing and interacting with our adverts, it is necessary to record and process the following parameters:

• Timestamps of when adverts were served (used for frequency analysis)
• IP addresses of the users (used for fraud detection purposes)
• User agents of the users’ browsers (used for fraud detection)
• Countries the adverts were served to (used for detecting location anomalies)
• Publisher and page URL (used for detecting behavioural anomalies)
• Advert served and interactions with it (used for detecting behavioural anomalies)

No other personally identifiable information is used to analyse the viewers or their interactions with our adverts.

Balancing Test

We don’t have a direct relationship with the individual and we consider that using viewing parameters only to detect fraudulent activity is processing that an individual could reasonably expect to occur. The fact that we don’t associate or store these viewing parameters with any other personally identifiable information for the purposes of targeting adverts later, means that we do not consider the use of such parameters in this manner to be intrusive.

Summary

Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to your device.

Purpose Test

Advertisers use Smartology to deliver semantically relevant adverts to users solely based on the context of the pages the users are currently consuming and not by using any personal information about, or profiles of, the users themselves.

When a user consumes an article, our systems perform a search for an advert from the set of all qualifying adverts, choosing the advert with the highest semantic match between the content of that advert and the content of the article being consumed. We also apply proprietary brand safety technology to prevent an advertiser’s content being served next to publisher content on crime, terrorism, disasters etc.

Delivering contextually relevant adverts to users has the benefit of giving those users a more relevant and useful advertising experience which leads to higher engagement with those adverts.

Necessity Test

Our systems receive many signals in a bid request but to select the most semantically relevant advertiser item to the content being viewed, most of the data from this request is ignored. For the purpose of selecting the best advert, Smartology processes the following:

• The publisher and URL of the page the user is consuming (used to semantically match that article’s content against advertiser content using proprietary Natural Language Processing algorithms)
• The country in which the user is located (used to enable an advertiser to target their campaigns at specific countries)
• The id of the publisher app being used to access the content (used to enable an advertiser to target a specific publisher app)
• The device type of the user (used to enable an advertiser to target their campaigns specifically at mobile devices)

To allow the user to navigate to the advertisement’s landing page, it is necessary for our systems to redirect the user’s browser or app to that landing page when the user clicks on the advertisement.

Balancing Test

We don’t have a direct relationship with the individual and only serve adverts that are relevant to the article that the individual is viewing at that moment in time. We consider this to be non-intrusive as no historical or personally identifiable information is used in this process. We consider that selecting the most relevant advert using only the content being viewed and the country that it's being viewed in is processing that the user could reasonably expect to happen and allows us to meet regulatory requirements and observe GDPR. It also has the benefit of giving the user a more useful and pertinent advertising experience without using any private or sensitive information. When the individual clicks on an advert, the individual could reasonably expect to be taken to a landing page on the advertiser’s website. Children are excluded from advert targeting.

Summary

The choices you make regarding the purposes and entities listed in this notice are saved and made available to those entities in the form of digital signals (such as a string of characters). This is necessary in order to enable both this service and those entities to respect such choices.

Purpose Test

Advertisers use Smartology to deliver semantically relevant adverts to users solely based on the context of the pages the users are currently consuming and not by using any personal information about, or profiles of, the users themselves.

The saving and communicating of users’ privacy choices in the form of TC Strings is performed for the purpose of ensuring and being able to demonstrate that users have consented to or not objected to the processing of their personal data, for the purpose of delivering semantically relevant adverts.

Necessity Test

To act appropriately on individual user choices with regards to using and sharing data, we require the publisher hosting the user to share those choices with us in the form of a TC String. We observe these choices when making a decision on whether or not it is appropriate to serve an advertisement to a user.

Where an advertiser is using a third party vendor to measure their SmartMatch™ advertising campaign, we will apply a user’s choices - as declared in the TC String - against the GVL declarations made by those third party vendors. An advert will not be served where a vendor does not have appropriate consent, regardless of consent settings for Smartology Ltd. When an advert is served, Smartology passes the consent settings via the TC String to any third party vendor present in the advert, so that they may act according to a user’s wishes.

Smartology performs the following checks on the TC String when determining if the user has consented to an advert:

• Is the CMP valid?
• Is the policy version valid based on the TC String’s creation date?
• Is Purpose 2 (Select Basic Ads) consented for Smartology by both the user and publisher?
• Is Purpose 7 (Measure Ad Performance) consented for Smartology by both the user and publisher?
• Is Purpose 7 (Measure Ad Performance) consented for each third party vendor present in the advert by both the user and publisher?

When we determine that consent has been established for Smartology and the advert’s third party vendors and we serve that advert, we persist the TC String that was used in coming to that decision.

Balancing Test

We don’t have a direct relationship with the individual and only serve adverts that are relevant to the article that the individual is viewing at that moment in time. We consider this to be non-intrusive as no historical or personally identifiable information is used in this process. We consider that selecting the most relevant advert using only the content being viewed and the country that it's being viewed in is processing that the user could reasonably expect to happen and allows us to meet regulatory requirements and observe GDPR. It also has the benefit of giving the user a more useful and pertinent advertising experience without using any private or sensitive information. When the individual clicks on an advert, the individual could reasonably expect to be taken to a landing page on the advertiser’s website. Children are excluded from advert targeting.

Communicating an individual’s choices via the TC String with us means we are better able to honour those choices the individual has made.