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Abstract
This paper looks into the issues in ad tech activities from a data protection perspective, focusing on two of the standout lawful bases in General Data Protection Regulation: legitimate interest and consent. Automated systems are the backbone of most online advertising technologies and activities, and a great deal of personal data is being used to create ads for people. Legitimate interest and consent are being discussed controversially in relation to processing personal data in ad tech activities (especially in real-time biddings and cookies), and they create confusion and ambiguity for the majority of stakeholders. In this paper, while legitimate interest is discussed in detail, a brief examination of the challenges surrounding the collection of consent in ad tech is also included. Finally, potential remedies (in a general approach given the complexity of the technology) are suggested to overcome existing impediments.
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Author's Biography
Ezgi Pilavci is a privacy lawyer and is currently working at Privacy Culture Ltd. Ezgi completed her master’s degree in computer and communications law at Queen Mary London University, London, UK. She has double masters’ degrees in information technology law having six years of experience as an associate in a global law firm in Istanbul, Turkey. Ezgi has been involved in corporate and commercial matters, especially those focused on technology. She has much experience in drafting and revising different types of commercial contracts: SPAs, NDAs, comprehensive IT services, agreements and negotiations with the third parties. Ezgi advised multinational clients on the data protection compliance process. This includes preparing and delivering presentations on data protection principles, privacy requirements and drafting necessary legal texts: consent, policies and supported privacy impact assessment schemes.
Steve Wright is a workplace design professional with over 35 years’ experience in the provision of corporate offices, buildings and branded environments. His previous research has focused on the interaction of people and places enabling the development of insights into productivity, performance and employee satisfaction. It is this fascination with the changing world of what constitutes an effective workplace that fuels his ambitions to quantify the value of good design beyond the aesthetic. Steve is currently part of the CoreNet Global, London Chapter, Workplace Committee alongside his role leading the design team at TTSP in London, UK. He has previously presented his views at the European CoreNet Summit and been published in CREJ, Sustain Magazine, Mix, AJ Review and Building Design.