Balance of Interests Assessment

Updated on: March 31, 2025

Processing carried out on the basis of legitimate interest within the framework of the TCF v2.2.

In accordance with the guidelines of the European Data Protection Board (EDPB) and the requirements of the IAB Europe TCF, we present below our legitimate interest assessment for the purposes declared in the Global Vendor List (GVL).

This purpose aims to evaluate the effectiveness of advertising campaigns, by analyzing in particular:

Visits to the website or mobile site after exposure to a TV / radio advertisement,
The volume and nature of the traffic generated,
User engagement and conversions.

Data processed

Pseudonymous cookie ID,
Unique ID provided by the client (optional, for cross-device purposes),
IP address (real-time geolocation and then anonymization before storage),
Browsing information: URL visited, referrer, marketing events triggered via the tag,
User agent used only in real-time to identify the device (not stored).

Legitimate interest pursued

To allow our clients (advertisers, agencies) to:

Measure the return on investment of their campaigns,
Optimize their offline media plans (TV / Radio),
Reduce unnecessary advertising pressure.

Balance of interests

We believe that the interests of our clients do not override the rights of users, because:

The data is pseudonymized or anonymized quickly,
No individualized targeting is carried out,
The user can object to this processing via Consent Management Platforms (CMPs).

Identified risks

Exposure of a visitor's browsing history following potential re-identification from pseudonymous data

Safeguards and mitigation measures

Data minimization: collection strictly limited to what is necessary,
A different cookie for each website, allowing for the minimization of the risk of cross-site identification,
Encryption: all data is encrypted,
Anonymization of the IP address, non-retention of the user agent.

This purpose consists of analyzing the aggregated behavior of users in order to:

Understand the performance of a media or marketing channel,
Produce overall statistical reports for our clients,
Identify trends by region, device, or time of day.

Data processed

Aggregated data from visits (time, frequency, source),
Non-identifying technical data (device type, language, time zone),
URL and referrer,
Events defined by the client in our Tag.

Legitimate interest pursued

To provide our clients with a better understanding of their audiences,
To assist with strategic media planning,
To support a data-driven approach to advertising investment.

Balance of interests

The data does not allow for the personal identification of a user:

They are either anonymized or used for purely statistical purposes,
The user remains free to object to this processing at any time.

Identified risks

Exposure of a visitor's browsing history following potential re-identification from pseudonymous data

Safeguards and mitigation measures

Data minimization: collection strictly limited to what is necessary,
A different cookie for each website, allowing for the minimization of the risk of cross-site identification,
Encryption: all data is encrypted,
Anonymization of the IP address, non-retention of the user agent.

Exercise of rights

Users can exercise their right to object to the use of their data for these purposes via the CMPs integrated on partner sites or by contacting us at dpo@data-circle.eu.

You can also opt-out for all future tracking by Data Circle by visiting https://edi5on.com and checking the Do not track me checkbox