Lunio typically operates under the legitimate interest legal basis (Article 6(1)(f) GDPR) for the purpose of fraud detection and prevention. As fraud prevention is considered a necessary security function, this processing generally does not require prior user consent. However, customers should assess this within the context of their own legal and regulatory obligations.
GDPR and Legitimate Interest
Processing under legitimate interest means Lunio can run essential fraud prevention activity without requiring a user to provide consent first. In practice, this means:
Data collected is limited strictly to what is necessary for fraud detection
No cookies are used unless they are strictly necessary under applicable laws
The data is not used for marketing, profiling, retargeting, or other secondary uses
Controller and Processor Responsibilities
Understanding how responsibilities are divided between Lunio and the customer is important for ensuring your use of the platform aligns with your compliance obligations.
Lunio acts as a data processor, processing data on behalf of the customer
The advertiser (customer) acts as the data controller, determining the purpose and means of processing
What Advertisers Need to Do
As a data controller, your only requirement is to mention Lunio's fraud prevention tool in your privacy policy, along with a brief explanation that it is based on legitimate interest. There are two ways to approach this:
If you remove Lunio as a vendor from your CMP or consent prompt, update your privacy policy to mention Lunio's fraud prevention tool and note that it operates under legitimate interest
Alternatively, ensure that Lunio is listed under the legitimate interest category within your CMP or consent prompt
This information is provided for guidance only and does not constitute legal advice. Please consult your legal team if you have specific compliance requirements.
Data Protection Contact
For any data protection queries, please contact [email protected].
If you run into any issues, please reach out to your account manager or email [email protected] and we will be happy to help.