Legitimate Interest Test 

Introduction

SpinX Pte Ltd uses consent as the legal ground for most of its data processing activities under the IAB Transparency and Consent Framework (TCF) where feasible. However, for the specific purpose of “Delivery and presentation of advertising,” we utilize legitimate interests as the sole legal basis. This document outlines the Legitimate Interest Assessment (LIA) conducted following the ICO LIA template for this unique TCF purpose.

Part 1: Purpose Test

• Why do you want to process the data? To deliver and present targeted advertising which is integral to our business model.

• What benefit do you expect to get from the processing? Effective advertising generates revenue and supports our business sustainability by fulfilling contracts with advertisers and publishers.

• Do any third parties benefit from the processing? Yes, advertisers see a return on investment through targeted reach and publishers gain from ad revenue which supports their content creation.

• Are there any wider public benefits to the processing? Public benefits include the support of free content on the internet through advertising revenues, thus contributing to the accessibility of information.

• How important are the benefits that you have identified? These benefits are crucial for the economic viability of online publishing and advertising ecosystems.

• What would the impact be if you couldn’t go ahead with the processing? Without this processing, our ability to support publishers and advertisers would be severely diminished, impacting the broader digital content industry.

• Are you complying with any specific data protection rules that apply to your processing (e.g., profiling requirements, or e-privacy legislation)? Yes, we comply with GDPR, DPA 2018, and e-privacy regulations.

• Are you complying with other relevant laws? Yes, we adhere to local and international laws relevant to our operations.

• Are you complying with industry guidelines or codes of practice? Yes, including adherence to IAB guidelines.

• Are there any other ethical issues with the processing? We only process consented data and use legitimate interest strictly where necessary, minimizing ethical concerns.

Part 2: Necessity Test

• Will this processing actually help you achieve your purpose? Yes, the delivery of targeted advertising directly supports our purpose.

• Is the processing proportionate to that purpose? Yes, we limit data processing to what is necessary to achieve these advertising goals.

• Can you achieve the same purpose without the processing? No, targeted advertising inherently requires processing of this nature.

• Can you achieve the same purpose by processing less data, or by processing the data in a more obvious or less intrusive way? The data processed is minimized to what is essential for effective delivery of advertising.

Part 3: Balancing Test

• Nature of the personal data: The data processed does not include special category or criminal offence data. It is primarily technical data required for ad delivery, which is not highly private.

• Reasonable expectations: Individuals expect advertising as part of the online content experience. Our data processing aligns with these expectations and is transparently communicated through CMPs.

• Likely impact: The impact on individuals is minimal as the processing does not significantly affect their data privacy rights. Individuals maintain control through consent mechanisms.

• Can you offer individuals an opt-out? Yes, individuals can withdraw their consent at any time, aligning with GDPR requirements.

• Can you rely on legitimate interests for this processing? Yes, given the low level of intrusion and the necessity of processing for achieving the outlined benefits.

Conclusion The legitimate interest basis is justifiably used for the specific purpose of delivering and presenting advertising, as assessed through detailed LIA procedures. This document is available in hard copy upon request.