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Eskimi and GDPR

GPDR requires companies to have applicable legal basis for:
1. Any kind of user data used
2. All ways of how is that data used

In online advertising, companies normally use non-personally identifiable data (such as cookies, device IDs) to target users and measure ad performance.
In order to perform these activities, an applicable legal basis is needed. It is Eskimi, as well as most of the market, understanding that 2 legal basis are appropriate here: consent and legitimate interest.

Consent
Consent is when user says 'yes' to the kinds of data and to the ways of data. User can agree or deny to companies processing user data.

Legitimate interest

Legitimate interest is when a company must use user data to survive and it can not hurt the user in any way. User can object to legitimate interest claims.

How to achieve all this for companies?

There can be multiple ways of asking users for consent and/or showing legitimate interest declarations.  The most used one, and the one we use in Eskimi, is by using Transparency and Consent Framework (TCF).

What's TCF?
TCF is framework to pass if user consented and/or objected to legitimate interest to online advertising companies. It is not the law - it's how companies like Eskimi understand the law.

TCF consists of:
* CMP (consent management platform): actual popup where user sees and selects: data usage purposes, companies
* Preferences string: 
* Vendors: companies using user data

Here's a CMP example:
CMP example.png

 

When expanding on information, you can see what information might be used by the companies:
CMP example information.png

When expanding on purposes, you can see what will companies do with your information. Example from another CMP:
CMP example purposes.png

And here's yet another example of how vendors are presented:

CMP example vendors.png

Eskimi DSP ( Aktyvus Sektorius vendor name ) is part of the IAB approved TCF vendors. 

Global TCF vendor list: https://iabeurope.eu/vendor-list/

To sum up, TCF allows:
* Showing purposes - how will companies use data

* Showing types  - what data will those companies use

* Allowing user accept/reject usage of this data

* Passing user preferences to the companies

What do clients have to do ? 

Client page should have a CMP ( Consent Manager Platform ) integrated on the website and make sure that "Aktyvus Sektorius" is on the vendor list. CMP usually handles a lot of integration automatically and provides customisability in order to correctly generate the consent string.
Then, if user agrees with Eskimi data purposes and what data will be used, 

What if I don't use a TCF-based CMP ?

If you don't use a TCF-based CMP, you have 2 choices:
* integrate one. More information on manual integration without CMP can be found here: https://iabeurope.eu/tcf-for-publishers/ 
* Discuss with your legal if any other solution is applicable to you (some other consent management way). if yes, please reach out to us.

What are the GDPR countries ? Where does this apply ? 
GDPR applies to these countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Channel Isles, England, Northern Ireland, Scotland, and Wales.