Legitimate Interest Claim
Effective Date: August 24, 2025
1. Introduction
Experience Ten Kft. (“we,” “us,” or “our”) is committed to respecting and protecting your privacy. This document outlines our reliance on legitimate interests under Article 6(1)(f) of the GDPR as the legal basis for certain processing of personal data.
We process personal data to support our business operations—such as targeted advertising, service improvement, and fraud prevention—in a way that is proportionate, transparent, and respectful of your rights.
2. Purposes for Processing Personal Data
Consent-Based Purposes
We rely on consent for processing personal data in direct contexts such as:
Creating detailed profiles for personalized advertising
Selecting and delivering personalized ads
Legitimate Interest Purposes
For other operational purposes, we rely on legitimate interests, including:
Targeted Advertising & Ad Selection – we may use limited data to select and deliver ads more relevant to you.
Measuring Ad Performance – evaluating the effectiveness of our campaigns.
Understanding Audiences and Statistics – using aggregated data to gain insights into user behavior.
Service Improvement and Development – refining and enhancing user experience and platform functionality.
3. Special Purpose & Feature Declaration
We declare the following to align with transparency and user expectations:
Special Purpose – Advertising Efficiency: Measuring ad delivery, frequency capping, and detecting fraudulent activities.
Special Purpose – Personalization: Customizing ads and content based on inferred user preferences.
Special Purpose – User Privacy Respect: Ensuring all processing respects user privacy choices.
Features Declared:
Feature – Cross-Source Matching: Matching data from different sources to deliver more relevant content.
Feature – Device and Fraud Detection: Identifying device patterns to prevent abuse and fraud.
4. Legitimate Interests Assessment (LIA)
We conducted a Legitimate Interests Assessment (LIA) following recognized EU guidance, applying a three-part test covering purpose, necessity, and balancing of interests.
Purpose Test: Our processing supports legitimate business objectives—delivering relevant advertising and improving service.
Necessity Test: Processing is necessary because less intrusive alternatives (such as obtaining user consent in every instance) would limit effectiveness.
Balancing Test: We ensure users’ privacy rights are not overridden; processing is within expectations, essential for service provision, and supported by safeguards like anonymization and opt-outs.
5. Categories of Personal Data Processed
We may process:
IP address
Device identifiers (e.g., Advertising ID, GAID, IDFA)
Post-back data: ISP, geographic region, application details, device model, OS, etc., but only when linked with advertising identifiers
6. Data Security, Integrity, and Confidentiality
We ensure protection of your data with robust measures, including:
Data obfuscation
Secure storage and encryption
Access controls and detection of unauthorized access
7. User Rights & Transparency
We inform users in our Privacy Policy and Cookie Policy that we rely on legitimate interests, detailing what they are.
Users may object to direct marketing based on legitimate interests, and we will comply unless there is a compelling overriding reason.
We regularly review our Legitimate Interests Assessment and update it if our processing context changes.
8. Summary Table
Conclusion
After thorough assessment, we have determined that processing personal data for the above purposes aligns with our legitimate business interests and user expectations. Appropriate safeguards are in place, and user rights are respected. This Legitimate Interest Claim ensures that our practices are transparent, justified, and compliant with GDPR requirements.