Legitimate Interest Assessment (LIA) – WNSDY Media AB 

Date: March 02, 2026  
Company: WNSDY Media AB (WNSDY)  
Prepared by: Filip Grimborg, CTO & Partner  
Legal basis in scope: Legitimate Interest under GDPR Art. 6.1(f) for Purpose 7 (Measure advertising performance) in IAB TCF v2.3. 


1. Description of the legitimate interest pursued 


WNSDY Media AB (559211-4994) acts as an in-house manager and reseller for selected publishers. We package and forward advertising inventory and consent signals (“pass as is”) to buyers via SSP accounts (PubMatic, Adform). 


To fulfill this service, we need to measure advertising performance (Purpose 7), which includes analyzing metrics such as impressions, fill rate, CPM, viewability, and revenue optimization. This enables us to provide accurate reporting to publishers and optimize SSP configurations for better earnings. 


We do not declare Legitimate Interest for Special Purposes 1 (security/fraud/errors) or 2 (deliver advertising/content), as these are handled by our underlying SSP vendors (PubMatic, Adform), who declare LI for these purposes in their own GVL entries. 


2. Necessity test 


Is the processing necessary to achieve the legitimate interest? Yes. Without performance measurement (Purpose 7), we cannot: 


  • Deliver accurate revenue and performance reporting to publishers. 


  • Identify trends and optimize bid flows/SSP settings for improved fill rate and CPM. 


  • Fulfill our contractual obligations to maximize publisher earnings. 


The processing is strictly limited to pseudonymized/hashed technical identifiers (e.g., cookie-ID, device-ID) forwarded from the publisher according to their consent signals. No additional collection, profiling, or cross-publisher data combination occurs. 


3. Balancing test 


Do the interests or fundamental rights and freedoms of data subjects override our legitimate interest? No – the legitimate interest outweighs the impact on data subjects for the following reasons: 


  • Nature of data: Pseudonymized/hashed technical identifiers (no direct personal identifiers, no sensitive data). 


  • Impact on data subjects: Minimal. Data is used solely for technical performance measurement and optimization – not for profiling, targeting, or marketing to individuals. No re-identification occurs on our side. 


  • Reasonable expectations: Data subjects expect ads to be delivered, measured, and optimized for site monetization when visiting publisher sites. Consent/LI is obtained by the publisher via their CMP. 


  • Safeguards applied: 


  • Data is forwarded “pass as is” without modification or additional storage beyond SSP platform handling. 


  • Retention limited to max 365 days (for performance reporting and trend analysis). 


  • No combination of data across publishers or creation of user profiles. 


  • Reliance on SSP platforms’ security measures and compliance (PubMatic/Adform DPA/SCC). 


  • No active fraud detection or device scanning on our side (handled by SSP vendors). 


Conclusion: The processing under Purpose 7 is necessary, proportionate, and does not override the interests, rights, or freedoms of data subjects. Legitimate Interest is the appropriate legal basis. Special Purposes 1 & 2 are not declared by us, as they are covered by our SSP partners. 


Approved by: XXXX 
Date: March 02, 2026