Contract analysis

Section 1: Document Control and Version History 1.1 Version Table This Data Protection Impact Assessment ("DPIA") has been prepared by Calderwood & Harkness LLP ("C&H") on behalf of Aurelius Global Media Group PLC ("AGMG" or the "Company") in connection with the Company's programmatic advertising processing activities across its European digital properties. The version history of this DPIA is set forth below. Reason

Section 2: Introduction and Regulatory Context 2.1 Purpose of This DPIA This DPIA is conducted pursuant to Article 35 of Regulation (EU) 2016/679 (the "General Data Protection Regulation" or "GDPR") and the equivalent provision retained in United Kingdom law by the UK GDPR, as supplemented by the Data Protection Act 2018 (the "DPA 2018"). Article 35(1) GDPR mandates that a controller carry out an assessment of the im

Section 3: Description of the Processing 3.1 Nature of Processing AGMG's programmatic advertising activities involve the automated buying, selling, and placement of digital advertisements through real-time bidding ("RTB") auctions. RTB is a process by which digital advertising inventory is bought and sold on a per-impression basis through automated, instantaneous auctions that occur in the milliseconds between a user

Section 4: Legal Basis for Processing 4.1 Consent — Article 6(1)(a) GDPR and ePrivacy Directive Article 5(3) The primary legal basis for all programmatic advertising processing activities conducted by or on behalf of AGMG is explicit, informed, freely given, and unambiguous consent obtained pursuant to Article 6(1)(a) GDPR, read in conjunction with Article 5(3) of the ePrivacy Directive (as transposed into the nation

Section 5: Necessity and Proportionality Assessment 5.1 Necessity

Article 35(7)(b) GDPR requires this DPIA to include an assessment of the necessity and proportionality of the processing operations in relation to their purposes. The necessity assessment considers whether the processing is genuinely needed to achieve the identified purposes and whether the same objectives could be achieved through less intrusive means. Programmatic advertising is a core component of AGMG's digital m