Legitimate Interest Assessment (LIA) & Disclosures

Last Updated: January 2026

In Compliance with IAB TCF v2.3

This page provides the legal justification for the processing activities where Three Spring Media LTD (“LightAd”) relies on Legitimate Interest as a legal basis under Article 6(1)(f) of the GDPR.

1. Our Approach to Legitimate Interest

Following the industry transition to TCF 2.3, LightAd has removed Legitimate Interest as a legal basis for any purpose related to Personalization (Purposes 3, 4, 5, and 6). We now only rely on Legitimate Interest for the “Special Purposes” essential to the technical integrity, security, and delivery of our services.

2. Special Purpose 1: Security, Fraud Detection, and Debugging

Interest: To protect our advertising partners from financial loss due to non-human traffic (bots) and to ensure the technical stability of our systems.

• The Purpose Test: We process technical data (such as IP addresses and User Agents) to distinguish between legitimate human users and automated bots. This prevents fraudulent charges for our advertisers.
• The Necessity Test: There is no alternative way to verify the authenticity of an ad request in real-time bidding without processing these technical signals.
• The Balancing Test: The data processed is strictly technical and pseudonymized. It is not used for profiling or marketing. The benefit of a secure, fraud-free internet ecosystem outweighs the minimal privacy impact on the individual.

3. Special Purpose 2: Delivery of Advertising

Interest: To technically transmit the advertisement from our servers to your device.

• The Purpose Test: We must process the user’s IP address to know where to send the ad-file (creative) and to confirm that it was successfully rendered.
• The Necessity Test: Without processing the IP address, an ad-file cannot be routed through the internet to the user’s browser or app.
• The Balancing Test: This is a transient technical operation. The data is used for the immediate delivery of the service the user is interacting with (supported by ad-revenue) and does not result in a permanent profile.

4. Purpose 2: Basic Ad Selection (Contextual)

Interest: To show ads that are relevant to the content being viewed, without tracking the user over time.

• The Purpose Test: We use the URL of the website or the Category of the App (e.g., “News” or “Sports”) to select a relevant ad.
• The Necessity Test: To remain viable, the digital ecosystem requires ad-supported content. Basic contextual ad selection is the least intrusive way to fund this content.
• The Balancing Test: No past browsing history or personal profiles are used. The ad is selected based on the current page only, which aligns with reasonable user expectations.

5. Special Purpose 3: Save and Communicate Privacy Choices

Interest: To remember and respect the privacy choices you make in a Consent Management Platform (CMP).

• The Purpose Test: We process the “TC String” to ensure we do not track you if you have said “No.”
• The Necessity Test: Without this processing, we would have no way to know your preferences and might accidentally process data against your wishes.
• The Balancing Test: This processing directly supports user rights and privacy. It ensures your choices are honored across the advertising supply chain.

6. How to Object

Under GDPR, you have the Right to Object to any processing based on Legitimate Interest.

• Via CMP: You can exercise this right through the “Privacy Settings” or “Vendors” tab on any website or app using our services.

Direct Request: You may also email us at [email protected].