Legitimate Interests Disclosure
URL: legitimate-interest
Last updated: 14 October 2025
At Tunnl BV, we are committed to ensuring transparency and compliance with the EU General Data Protection Regulation (GDPR) and other applicable data protection laws.
This page explains where we rely on legitimate interest as a lawful basis for processing personal data, why we do so, how this affects you, and how you can exercise your rights.
What Is Legitimate Interest
Under Article 6(1)(f) GDPR, Tunnl BV may process personal or pseudonymous data when it is necessary for our legitimate business interests, provided these do not override your fundamental rights and freedoms.
Before relying on this basis, we perform a Legitimate Interest Assessment (LIA) to ensure fairness, necessity, and balance between our business purposes and user privacy.
We rely on legitimate interest only for processing that:
Is necessary to provide and secure our advertising technology services.
Uses pseudonymous or aggregated data wherever possible.
Has minimal impact on individual users’ privacy.
Purposes for Which We Rely on Legitimate Interest
Tunnl processes limited categories of data under legitimate interest for the following purposes:
Purpose | Description |
|---|---|
Ad Delivery and Frequency Capping | Delivering standard (non-personalized) advertising, ensuring correct ad placement, and preventing repetitive ad display. |
Measurement and Reporting | Aggregating impressions, viewability data, and campaign results to measure ad effectiveness without identifying individual users. |
Fraud Detection and Prevention | Detecting invalid traffic, bot activity, and ensuring platform integrity. |
Security and Platform Operation | Maintaining the reliability, uptime, and functionality of our technology systems. |
Service Optimization | Using pseudonymous data to analyze performance trends and improve delivery algorithms and user experience. |
These activities are fundamental to maintaining a fair and efficient digital advertising ecosystem that benefits publishers, advertisers, and end-users.
Types of Data Processed Under Legitimate Interest
When relying on legitimate interest, we may process limited pseudonymous or technical identifiers, such as:
IP addresses (in truncated or anonymized form);
Cookie or device identifiers;
User agent strings and browser type;
Ad request, impression, click, and conversion events;
Aggregated performance and fraud signals.
We do not use sensitive personal data for these purposes and we do not perform personalized or behavioral targeting without user consent.
How We Safeguard Your Rights
We apply several safeguards to protect your privacy when processing under legitimate interest:
Data minimization – collecting only what is necessary for each purpose.
Pseudonymization – avoiding direct identifiers wherever possible.
Purpose limitation – using data only for clearly defined operational purposes.
Retention controls – deleting or anonymizing data once it is no longer needed.
Independent balancing tests – conducted regularly to confirm that our interests do not override your rights.
We also ensure all partners and vendors we work with apply equivalent protections.
Your Right to Object
You have the right to object at any time to processing based on legitimate interest. If you exercise this right, Tunnl will stop processing your data for the relevant purpose unless we demonstrate compelling legitimate grounds or need the data to establish or defend legal claims.
You can object by:
Adjusting your preferences in our Consent Management Platform (CMP), accessible from the “Manage Preferences” link on our website;
Sending an email to [email protected] with your objection request; or
Using the industry opt-out tools listed below:
When We Rely on Consent Instead
We do not rely on legitimate interest for all processing. Some activities always require your consent, including:
Storing or accessing cookies and device identifiers for tracking;
Personalized and behavioral advertising;
Audience segmentation, profiling, and retargeting.
Relationship with the IAB TCF
Tunnl BV follows the IAB Europe Transparency & Consent Framework (TCF v2.2) principles for transparency and signal handling. Although we do not operate a CMP ourselves, we receive and process consent strings from partner CMPs used by publishers and supply-side platforms. We honor these signals when processing data under legitimate interest and when identifying where consent is required instead. Once registered as a TCF Vendor, our Vendor ID and declared purposes will be published on this page.
Tunnl is a participant in the IAB Europe Transparency & Consent Framework (TCF v2.2), which standardizes how consent and legitimate interest are communicated across the digital advertising industry.
Our Vendor ID and CMP ID (once assigned) will be published on this page.
Contact Information
If you have questions about this disclosure or how we rely on legitimate interest, please contact us at:
You may also reach our Data Protection Officer (if applicable) at the same address, marking your request as “GDPR – Legitimate Interest Inquiry.”
Updates to This Page
TCF Compliance Status
Tunnl BV currently operates as a GDPR-compliant ad technology intermediary that respects the TCF consent signals transmitted by our partners. We are in the process of finalizing IAB Vendor registration to achieve full technical TCF compliance.
We may update this page periodically to reflect changes in our practices or regulatory requirements. The latest version will always be available on this website, with the date of the most recent update shown above.