Thread · 4 tweets · 2 May 2018

I did not say "usually". My strictly personal appraisal is that it is possible to carry out advertising that does not threaten personality integrity through inappropriate flows of personal information, including up to extremely limited behaviour (very coarse).

Given sufficiently limited risks to data subjects and the necessity of ads in some business models I believe it possible to find this falling under legitimate interest.

Now as to the behavioural targeting in full regalia, my own view is that it would indeed require consent because of how comprehensive it is and how much sensitive data is involved, but since consent is only valid if informed I would contend that it only holds if...

...you regularly show the user how exactly you've profiled them and who has seen that profile. Otherwise it's too opaque. I stand by my recommendation: do not consent unless it's evidently OK. Would you disagree?