Legitimate Interest Claim

Metys — CTV Advertising Measurement

Effective: April 2026 · Last updated: April 12, 2026

1. Controller Identity

Metys is the data controller for the processing activities described in this document. Metys participates in the IAB Europe Transparency & Consent Framework (TCF) and complies with its Specifications and Policies.

Contact: privacy@metys.co

2. Purposes for Which We Claim Legitimate Interest

TCF Purpose	How we use it
Purpose 2 Use limited data to select advertising	Aggregated context-level performance data to inform contextual ad placement — not individual targeting.
Purpose 7 Measure advertising performance	Match hashed household identifiers across impression and visit events. Outputs are aggregated lift metrics.
Purpose 8 Measure content performance	Measure how exposed households engage with advertiser website content — pages visited, time spent, key interest pages reached.
Purpose 9 Understand audiences through statistics	Aggregated statistical insights: Interest Score breakdowns, frequency-lift curves, reach overlap analysis.
Purpose 10 Develop and improve services	Aggregated, de-identified data to refine measurement methodology and attribution models.
Purpose 11 Use limited data to select content	Contextual performance data for publishers/networks — based on historical aggregate data, not individual profiles.

3. Legitimate Interest Assessment

3.1 Purpose test — Is there a legitimate interest?

Yes. Metys provides independent, aggregated advertising measurement serving three legitimate interests:

Advertisers — understanding whether media spend drives real engagement.
Publishers/networks — demonstrating inventory effectiveness to advertisers.
General public — sustaining a healthier ad-supported media ecosystem.

3.2 Necessity test — Is the processing necessary?

Household-level attribution requires a common identifier across impression and visit events.
We use one-way SHA-256 hashing — the least intrusive method available.
Hash computed at the network edge — raw IP never reaches our backend.
No cookies, device fingerprinting, advertising IDs, or persistent identifiers used.

3.3 Balancing test — Do individuals’ rights override?

Factor	Assessment
Identification risk	Negligible. SHA-256 is irreversible. No lookup table exists.
Individual profiling	None. All outputs are aggregated campaign-level statistics.
Decisions about individuals	None. No individual is targeted, scored, or segmented.
Sensitive data	None. No special categories processed.
Cross-device tracking	None at individual level. Household-level only.
Device storage	None. No cookies or client-side storage.
Data retention	365 days max. Automatically deleted.
Data sharing	Minimal. Reports contain only aggregated statistics.
Reasonable expectations	Aligned. Users can expect ad effectiveness to be measured in aggregate.

4. Safeguards

Edge-level SHA-256 pseudonymisation (Cloudflare Worker)
TLS 1.3 in transit, encryption at rest
No cookies, advertising IDs, or device fingerprints
Aggregation by design — all outputs are statistical summaries
TCF consent/opt-out signals honoured in real time
Global Privacy Control (GPC) signals honoured
Automatic 365-day data deletion
Need-to-know access controls
Right to object: privacy@metys.co

5. Conclusion

Metys confirms that the legitimate interests pursued are not overridden by the interests, rights, or freedoms of data subjects, given the pseudonymised and minimal nature of the data processed, the privacy-preserving techniques employed, and the aggregated nature of all outputs.

6. Contact

privacy@metys.co · metys.co

We will respond within 30 days.