Organization:

Realytics SAS

Purpose:

Realytics SAS plans to monitor and analyze website traffic and user interactions coinciding with the broadcast of their TV campaign to assess the campaign’s effectiveness in driving web engagement and to optimize future marketing strategies.

Legitimate Interests Identified:

Assessing and enhancing the effectiveness of TV advertising on website engagement.

Optimizing future marketing campaigns based on data-driven insights.

Improving user experience on the website by understanding how users engage with content related to the TV campaign.

Necessity Test:

Question: Is the processing of personal data for monitoring website traffic and interactions during a TV campaign broadcast necessary for achieving the identified legitimate interests?

Assessment:

Monitoring website traffic and interactions is necessary to directly measure the impact of the TV campaign on web engagement.

Analyzing this data is essential for Realytics SAS to make informed decisions on marketing strategies and to tailor future content more effectively to user interests.

Balancing Test

Interests and Rights of Data Subjects (Website Users):

Website users have a right to privacy and control over their personal data.

Users expect transparency and fairness in how their data is processed, particularly in how their online activities are monitored and analyzed.

Potential Impact on Data Subjects:

Monitoring user behavior on the website raises concerns about privacy and data protection.

Users may feel their consent is bypassed if they are not adequately informed about the monitoring activities and the purposes behind them.

Safeguards and Mitigation Measures:

Implementing a transparent and accessible privacy policy that clearly explains the monitoring activities, the purpose behind them, and how data will be used to analyze the impact of TV campaigns.

Ensuring that data collection is limited to what is strictly necessary to achieve the purpose of assessing the TV campaign’s effectiveness.

Providing users with clear, accessible options to opt-out of data tracking and analysis related to the TV campaign.

Utilizing anonymization or pseudonymization techniques to minimize the risk of identifying individual users from the collected data.

Conducting regular privacy impact assessments to ensure ongoing compliance with privacy regulations and to reassess the necessity and proportionality of the monitoring activities.

Conclusion:

Realytics SAS concludes that with the implementation of clear transparency measures, user opt-out options, and data protection safeguards, the legitimate interests of analyzing the effectiveness of TV campaigns through website monitoring do not override the privacy rights and freedoms of website users. The decision, along with the detailed LIA, is documented thoroughly to demonstrate compliance with TCF requirements and GDPR obligations.

Documentation and Compliance

Realytics SAS documents the LIA process comprehensively, including the legitimate interests pursued, the necessity and proportionality of the data processing, the conducted balancing test, and the implemented safeguards to protect user data. This documentation is crucial for demonstrating adherence to TCF Purpose 5 requirements and GDPR, ensuring that Realytics SAS can validate its data processing activities as lawful, fair, and transparent.

Organization

Realytics SAS

Purpose

Realytics SAS seeks to combine data from website analytics, TV campaign metrics, and external demographic sources to create detailed audience profiles. These profiles will inform content personalization, advertising strategies, and product development, aiming to enhance user engagement and business growth.

Legitimate Interests Identified

Creating a comprehensive understanding of audience segments to tailor marketing and content strategies effectively.

Enhancing product development and customization based on insights into audience preferences and behaviors.

Improving overall user experience by aligning content and products with the interests and needs of different audience segments.

Necessity Test

Question: Is the processing of combined data from different sources necessary for achieving the identified legitimate interests?

Assessment:

Combining and analyzing data from multiple sources is necessary to achieve a holistic understanding of the audience that cannot be attained through single-source data. This comprehensive view is crucial for developing effective, targeted marketing strategies and product offerings.

The insights gained from this integrated analysis are essential for optimizing user experience and ensuring the relevance of the content and advertisements presented to different audience segments.

Balancing Test

Interests and Rights of Data Subjects (Audience Members):

Audience members have a right to privacy, including how their data is combined and analyzed for profiling.

There is an expectation of transparency and fairness in the use of their data, particularly concerning how information from various sources is integrated and used to influence content and product offerings.

Potential Impact on Data Subjects:

There could be privacy concerns related to the aggregation and analysis of data from diverse sources, especially if individuals are not aware of how their information is being combined and used.

The use of combined data for profiling could potentially lead to discriminatory practices or unwanted personalization.

Safeguards and Mitigation Measures:

Implementing robust data anonymization and pseudonymization techniques to minimize the risk of identifying individual audience members from the aggregated data.

Providing clear and comprehensive information to users about the data collection, combination processes, and the purpose behind these activities, ensuring transparency and informed consent.

Offering easy and accessible options for users to opt-out of data combination and analysis for audience understanding purposes.

Ensuring strict data access and processing policies to prevent unauthorized use of the combined data and to protect the privacy of audience members.

Regularly reviewing the data processing activities to ensure they remain necessary, proportional, and in line with the latest privacy regulations and best practices.

Conclusion:

InsightMetrics Inc. concludes that, with the implementation of stringent data protection measures and transparency towards audience members, the legitimate interests of understanding audiences through the combination of data from different sources do not override the privacy rights and freedoms of individuals. The decision to proceed, alongside the detailed LIA, is thoroughly documented to demonstrate compliance with TCF requirements and GDPR obligations.

Documentation and Compliance

InsightMetrics Inc. documents the entire LIA process, including the purposes of data combination, the necessity and proportionality of the processing activities, the conducted balancing test, and the safeguards implemented to protect individual privacy. This comprehensive documentation serves as a crucial foundation for demonstrating adherence to TCF guidelines and GDPR, ensuring that InsightMetrics Inc.’s approach to understanding audiences through statistics and data combination is both lawful and respectful of individual rights.