Legitimate Interest Assessment (LIA)

Scope: IAB TCF Purposes 2, 7, 10 and Special Purposes 1, 2, 3.

1. The Purpose Test (Identifying the Interest)

• Purpose 2 (Basic Ad Selection): Our interest is to facilitate the real-time selection of advertisements based on context and auction dynamics (highest bidder) to ensure the technical delivery of ads on behalf of publishers.
• Purpose 7 (Measurement): We have a business interest in logging ad impressions and clicks to provide accurate billing and performance reporting to our partners.
• Purpose 10 (Service Improvement): We process limited data to debug our proprietary Prebid fork, optimize server latency, and ensure our ad server remains compatible with evolving browser standards.
• Special Purposes 1, 2, & 3: We have a critical interest in preventing ad fraud (IVT), technically delivering ad files to IP addresses, and ensuring that user privacy choices (TC Strings) are respected across the ecosystem.

2. The Necessity Test (Assessment of Need)

• Operational Necessity: The processing of limited data (e.g., IP address, User-Agent, and non-precise location) is technically required for an ad server to respond to a bid request and deliver a compatible ad file.
• Less Intrusive Alternatives: We have specifically opted not to create user profiles (Purposes 3/4) or perform cross-device linking (Feature 2). Using Basic Ads via legitimate interest is the least intrusive way to maintain ad-supported content without behavioral tracking.
• Data Minimization: We only retain processing logs for 90 days, which is the minimum period necessary for financial auditing and troubleshooting.

3. The Balancing Test (Impact on the Individual)

• Nature of the Data: We do not process Sensitive Personal Data or Precise Geolocation. We strictly use non-precise location and transient device identifiers.
• Reasonable Expectations: Users browsing ad-supported websites reasonably expect that technical data will be processed to deliver an ad and that basic performance (like did the ad load?) will be measured.
• User Control: We strictly adhere to the IAB TCF. If a user signals an objection to Legitimate Interest via a CMP, our server is technically configured to stop processing for that user.

Conclusion

The limited impact on user privacy is outweighed by the necessity of these technical functions to maintain a secure, transparent, and functional ad-supported internet.