Legitimate Interest Claim Document for DOOH and CTV Verification Vendor (TCF)

1. Name of Organization: Thorndyke Pty Ltd
2. Date: 2024-11-15
3. Description of Processing Activity:

Thorndyke processes personal data in the course of providing verification services for digital out-of-home (DOOH) and connected TV (CTV) advertising. This involves collecting and analyzing data related to ad impressions, plays, audience demographics, and environmental factors to ensure accurate measurement and reporting of advertising campaigns across both mediums.

DOOH Data Processing:

As described previously, this includes collecting device information, environmental data, and campaign data related to DOOH ad displays.

CTV Data Processing:

In the CTV environment, our VAST wrapper technology allows us to collect data related to:

• • Device Information: Including device IDs, operating system, browser information, and IP address (which may be used to derive general location information).
  • Ad Playback: Such as ad completion rates, video engagement metrics (e.g., pauses, rewinds), and time spent viewing ads.
  • User Interactions: Data on user interactions with interactive ad elements.
  • Content Context: Information about the content being streamed alongside the ad, which helps understand the viewing context.

4. Purposes of Processing:

The primary purposes of processing this data across DOOH and CTV are:

• • Cross-Channel Measurement: To accurately measure and compare the reach, frequency, and performance of advertising campaigns across DOOH and CTV.
  • Audience Verification: To verify that ads are delivered to the intended target audience across both mediums.
  • Performance Optimization: To analyze campaign performance and provide insights to advertisers for optimization across both channels.
  • Unified Reporting: To generate comprehensive reports that provide a holistic view of campaign performance across DOOH and CTV.
  • Attribution Modeling: To better understand the customer journey and attribute conversions across DOOH and CTV touchpoints.

5. Legitimate Interests Pursued:

Thorndyke relies on legitimate interest as the lawful basis for processing personal data in the context of DOOH and CTV verification. Our legitimate interests include:

• • Providing Holistic Measurement Solutions: Offering advertisers a comprehensive view of campaign performance across DOOH and CTV is crucial for effective media planning and optimization in a converging media landscape.
  • Enhancing Industry Transparency: Providing accurate and reliable cross-channel measurement fosters transparency and trust in both the DOOH and CTV advertising ecosystems.
  • Driving Innovation: By analyzing data across both mediums, we can identify trends, develop new measurement methodologies, and drive innovation in the advertising industry.

6. Necessity and Proportionality:

The processing of personal data is necessary for achieving the purposes outlined above. We collect and process only the data that is strictly necessary for these purposes. We implement appropriate technical and organizational measures to ensure data security and minimize the risks to individuals’ privacy. We also apply data minimization principles and anonymize or aggregate data whenever possible.

7. Balancing of Interests:

We have carefully considered the potential impact of our processing activities on individuals’ rights and freedoms. We believe that our legitimate interests in providing accurate cross-channel measurement, combating fraud, and improving campaign performance outweigh any potential risks to individuals’ privacy. This is because:

• • Aggregated and Anonymized Data: We prioritize the use of aggregated and anonymized data to minimize the risk to individual privacy.
  • Transparency and Control: We are transparent about our data processing activities and provide individuals with clear information about their rights, including the ability to opt-out of data collection where appropriate.
  • Industry Best Practices: We adhere to industry best practices and guidelines for data privacy and security in both DOOH and CTV advertising.

Review and Update:

This Legitimate Interest Claim document will be reviewed and updated periodically or as required to ensure it remains accurate and reflects our current data processing activities.