Legitimate Interest Assessment (LIA)
Vendor: Relevant Digital Oy
Service: Relevant Yield
1. Scope of LIA and Description of Processing
Relevant Digital operates Relevant Yield, a technology platform used by digital publishers to optimise programmatic advertising auctions and manage advertising demand sources.
The purpose of this legitimate interest assessment (LIA) is to document a three-step assessment process under the EU General Data Protection Regulation (GDPR) and determine whether Relevant Digital can lawfully process personal data based on Article 6(1)(f) of the GDPR, i.e. legitimate interests. The scope of this LIA involves justifying the purpose of data processing, ensuring the necessity of the data collected and balancing those interests against the rights and freedoms of individuals within the context of Relevant Yield.
The platform processes limited pseudonymised data signals in order to:
- optimise advertising auctions
- select advertising based on limited contextual signals
- measure advertising performance
- develop and improve the Relevant Yield service
- ensure system security and detect fraudulent traffic
- technically deliver advertising and content to user devices.
The processing activities relate to the following IAB Transparency and Consent Framework (TCF) purposes:
- Purpose 2 – Use limited data to select advertising
- Purpose 7 – Measure advertising performance
- Purpose 10 – Develop and improve services
- Special Purpose 1 – Ensure security, prevent and detect fraud, and fix errors
- Special Purpose 2 – Deliver and present advertising and content
2. Purpose test
Relevant Digital and its publisher clients pursue the following legitimate interests:
- Monetisation of digital publishing services: Publishers rely on programmatic advertising revenues to fund digital content and services. The Relevant Yield platform enables publishers to maximise advertising yield and efficiently monetise advertising inventory.
- Operation of an efficient programmatic advertising marketplace: Relevant Digital has a legitimate interest in operating a competitive advertising platform capable of optimising advertising auctions across multiple demand partners and technical parameters.
- Improving user experience and performance: The platform optimises auction latency, bid participation and advertisement viewability to reduce unnecessary bid requests, improve page load speed and enhance user experience.
- Product improvement and innovation: Relevant Digital processes aggregated and pseudonymised data to improve the quality of its algorithms and develop new machine-learning-based optimisation models.
- Security and fraud prevention: Monitoring network behaviour and traffic patterns enables the detection of fraudulent traffic (e.g. bots, invalid ad clicks) and helps ensure the integrity and reliability of the advertising ecosystem.
- Technical delivery of content and advertising: Device signals and contextual information are required to ensure that advertising and content can be delivered and rendered correctly on different devices and platforms.
These interests constitute legitimate commercial and operational interests recognised within the digital advertising ecosystem. These legitimate interests pursued cannot reasonably be achieved just as effectively by other means less restrictive of the fundamental rights and freedoms of data subjects.
Within the IAB Transparency and Consent Framework, Relevant Digital relies on following purposes and special purposes:
- Purpose 2 (using limited data to select advertising): Advertising presented to you 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 7 (measuring advertising performance): 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 10 (developing and improving services): Information about your activity, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This specific purpose does not include the development or improvement of user profiles and identifiers.
- Special purpose 2 (delivering and presenting advertising and content): 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.
3. Necessity Test
Under GDPR Article 6(1)(f), processing must be necessary to achieve the identified legitimate interests.
Relevant Yield requires limited data signals to operate real-time programmatic auctions and deliver advertising content.
The data processed may include:
- pseudonymised identifiers (e.g. cookie IDs)
- device and browser information
- page or application context
- non-precise geolocation (country-level)
- advertising interaction and performance metrics
- auction configuration and bidding data.
These data elements are necessary for the following technical operations:
The data processed may include:
- Auction optimisation: The platform applies optimisation algorithms that adjust auction parameters such as floor prices, latency thresholds and demand partner participation based on historical and real-time signals.
- Real-time auction configuration: Relevant Yield enables publishers to configure auctions dynamically using contextual information such as page content, device type and location signals.
- Performance measurement: Advertising performance data (e.g. viewability or interaction signals) is necessary to evaluate the effectiveness of advertising campaigns and optimise auction outcomes.
- Fraud prevention: Security monitoring processes analyse traffic patterns and identifiers to detect invalid or malicious activity.
- Product development: Aggregated and pseudonymised data is used to improve algorithms and develop new features that improve platform performance.
Without this limited processing, the Relevant Yield platform would not be able to operate effectively as a real-time auction optimisation system.
Relevant Digital applies data minimisation principles, processing only signals necessary for the relevant technical operations.
4. Balancing Test
The balancing test evaluates whether the legitimate interests identified above are overridden by the rights and freedoms of data subjects.
- Nature of the data: The processing involves pseudonymised identifiers and contextual signals rather than directly identifiable personal information. Relevant Digital does not process names, email addresses, precise location data or sensitive personal data categories. Relevant Digital also states that it cannot re-identify individual users from the data processed. This significantly reduces potential risks to individuals.
- Reasonable expectations of data subjects: Users visiting publisher websites that contain advertising generally expect that advertising will be displayed, advertising performance may be measured and that advertising systems may use limited technical signals to optimise delivery. These expectations are reinforced through publisher privacy notices and consent management platforms (CMP) implementing the IAB TCF. The processing is therefore broadly consistent with user expectations in advertising-supported online services.
- Impact on individuals: The impact on individuals is limited because processing is pseudonymised, data is used primarily for technical optimisation and advertising delivery, processing does not involve profiling for sensitive characteristics and no direct identification of individuals occurs.
- Data subject rights: Data subjects retain their rights under the GDPR, including right to information, right of access, right to erasure and right to object to processing based on legitimate interests. Users may exercise these rights through publishers’ CMP or by contacting Relevant Digital.
- Safeguards and mitigation measures: Relevant Digital implements multiple safeguards, including:
- Data minimisation: Only limited pseudonymised signals necessary for auction optimisation are processed.
- Security monitoring: Security systems monitor traffic patterns to detect fraudulent activity or technical anomalies.
- Contractual safeguards: Publishers must ensure lawful data collection and provide transparency to users before transferring data to Relevant Digital.
- Framework governance: Processing is aligned with the IAB Europe Transparency and Consent Framework.
- Transparency: Relevant Digital provides privacy information explaining the data processing and user rights.
5. Conclusion
Following the three-step assessment:
- Relevant Digital and its clients pursue legitimate commercial and operational interests in operating the Relevant Yield advertising platform.
- The processing of limited pseudonymised data is necessary to achieve these interests.
- The rights and freedoms of data subjects are not overridden due to the limited nature of the data processed, the safeguards in place and the expected context of advertising-supported online services.
Accordingly, Relevant Digital may rely on Article 6(1)(f) GDPR as the lawful basis for the processing activities described above.