Legitimate Interest Statement
1. Introduction
TTG International LLC (“TTG”, “we”, “our”, or “us”) participates in the IAB Europe Transparency & Consent Framework (TCF) and declares certain processing activities under the legal basis of Legitimate Interest pursuant to Article 6(1)(f) of the EU General Data Protection Regulation (GDPR).
This document explains why we rely on legitimate interest, for which processing purposes, and how users can exercise their rights.
2. Why We Rely on Legitimate Interest
Our legitimate interests arise from the need to ensure the security, integrity, and efficiency of our advertising platform, while minimizing any impact on individuals’ rights and freedoms.
We process certain limited data for purposes that are necessary for normal business operations, measurement, and fraud prevention, where obtaining individual consent would not be practical or proportionate.
We have conducted a Legitimate Interest Assessment (LIA) balancing test to ensure that:
- The processing is necessary to achieve the stated purposes;
- It has minimal privacy impact on individuals;
- The users’ interests and fundamental rights are not overridden by our legitimate interests;
- Individuals always retain the right to object to such processing.
3. Processing Purposes Under Legitimate Interest
TTG relies on legitimate interest for the following purposes, consistent with the IAB Europe TCF Purposes:
- Purpose 2 – Select basic, non-personalised ads: Necessary to enable delivery of contextually relevant advertising where no personal data is used.
- Purpose 7 – Measure ad performance: Required for campaign reporting, frequency capping, and aggregate analytics.
- Purpose 8 – Measure content performance: Needed to understand ad placement effectiveness and ensure brand safety.
- Purpose 9 – Apply market research to generate audience insights: Used only in aggregated form to improve advertising effectiveness.
- Purpose 10 – Develop and improve products: Necessary to maintain and enhance Electorix systems, detect errors, and improve algorithms.
- Special Purpose 1 – Ensure security, prevent fraud, and debug: Required to detect invalid traffic, prevent abuse, and secure our systems.
4. Data Minimisation and Safeguards
We apply strict safeguards to protect user privacy:
- Use of pseudonymisation and data aggregation wherever possible.
- Short data retention periods aligned with operational necessity.
- No data sharing with third parties outside contractual or TCF-compliant partners.
- Continuous security monitoring and access controls.
5. User Rights and Objection Mechanism
Users have the right to object at any time to processing based on legitimate interest. To exercise this right, users can:
- Visit our privacy portal: https://www.timetogrow.io/privacy-policy.html
- Contact our Data Protection Officer (DPO) at: privacy@timetogrow.io
If you submit an objection, we will cease processing your data for legitimate interest purposes unless we can demonstrate compelling legitimate grounds to continue, or unless processing is required by law.
6. Contact
If you have any questions regarding this statement or our data processing practices, please contact:
TTG International LLC.
Data Protection Officer
Email:
privacy@timetogrow.io
Website:
https://timetogrow.io