Scope of the LIA
Data processing in the context of Readpeak’s platform for programmatic advertising.
Data Controller
Readpeak Oy
Description of data processing:
Personal data collected and processed consists of Cookie IDs and anonymized IP addresses, and of technical data connected to the browser. Readpeak processes the data to provide advertising services to its clients. For this aim, data is used for targeting and tailoring advertising, for optimizing advertising efficiency, and for providing analytics on advertising performance.
Purpose test (Are you pursuing a legitimate interest?):
Provision of programmatic advertising services is Readpeak’s core business. The services aim at making online advertising more efficient by optimizing the display of ads to suitable contexts. The services make online advertising experience also better for online audiences by showing them relevant content. If Readpeak were not able to carry on with the processing, it would be out of business. Also, it would make online advertising inefficient and irrelevant to online audiences and less cost-effective for advertisers. The processing of data is not considered unethical or unlawful as Readpeak does not accept advertising campaigns for content that is illegal or unethical.
Necessity test (Is the processing necessary for the above-stated purpose?):
The processing is essential for Readpeak to be able to provide the services, and therefore to Readpeak’s business in general. The processing is a reasonable way of achieving the goals and in line with processing activities of other demand-side platforms in the online advertising ecosystem. Currently, no less intrusive way exists for achieving the same result.
Balancing test (Do the data subjects’ interests override the legitimate interest?):
Due to the nature of the data processed, Readpeak has no real contact or relationship with the data subjects and no way of finding out their identities. The data processed is not particularly sensitive or private. In today’s world, people tend to take online targeted advertising for granted. Readpeak informs data subjects of the processing in a privacy policy on its website. People who are likely to find this kind of processing intrusive have the possibility of deleting cookies from their devices and can opt-out of data collection for Readpeak’s services on Readpeak’s website.
Conclusion (Can Readpeak rely on legitimate interests for this processing?):
Yes, Readpeak can rely on legitimate interests for the processing of data to provide programmatic advertising services.