Legitimate Interest Claim

BOTMAN INC

We, Botman Inc, are engaged in the business of cybersecurity software-as-a-service platform that specializes in advanced ad fraud detection and prevention for ad platforms, ad networks, advertisers and publishers. In accordance with the requirements of the IAB TCF, we hereby declare the Special Purpose for which we seek to establish a legal basis of legitimate interest for processing personal data.

All capitalized terms in this declaration shall bear the same meaning as defined in the IAB Europe Transparency and Consent Framework, 2023.

Our organization processes personal data under the following Special Purposes:

SPECIAL PURPOSES FOR PROCESSING

Special Purpose 1: Ensure security, prevent and detect fraud, and fix errors

We process personal data for activities necessary for:

1. Bot Detection: Identify and mitigate automated traffic generated by non-human agents (bots) that interfere with digital advertising campaigns and distort user engagement metrics.

2. Fraud Detection and Prevention: Detect and respond to fraudulent behaviors, including click fraud, impression fraud, ad stacking, and other practices that undermine the integrity and transparency of digital advertising systems.

3. Debugging and Optimization: Analyze data to identify and resolve technical issues, ensuring continuous improvement of fraud prevention and detection technologies.

Special Purpose 3: Save and communicate privacy choices

We process personal data for activities necessary for:

1. User Consent Management: Store and manage users' privacy preferences to ensure compliance with regulatory requirements and industry standards.

2. Transparency and Compliance: Facilitate the communication of privacy choices across digital advertising platforms to uphold user rights and regulatory obligations.
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3. ‍Preference Synchronization: Ensure that users' consent and privacy preferences are consistently applied across multiple platforms and services.

PURPOSES FOR PROCESSING UNDER LEGITIMATE INTEREST

1. STORE AND/OR ACCESS INFORMATION ON A DEVICE
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   IAB TCF Purpose: "Store and/or access information on a device" (Purpose 1)
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    Legitimate Interest Justification: To effectively detect and prevent fraudulent activities, we may store and/or access device information. This enables us to analyze behavioral patterns and identify fraudulent interactions, ensuring the security and integrity of digital advertising operations. This processing is essential to protecting our clients and maintaining trust within the digital advertising ecosystem. 
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2. ADVERTISING PERFORMANCE
   
   IAB TCF Purpose: "Measure advertising performance" (Purpose 7)
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   Legitimate Interest Justification: We analyze advertising performance to detect and prevent fraudulent activities, ensuring that ads reach genuine audiences and deliver intended outcomes. This process safeguards the interests of our clients by maintaining the integrity of their advertising efforts.
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3. CONTENT PERFORMANCE
   
   IAB TCF Purpose: "Measure content performance" (Purpose 8)
   
   ‍Legitimate Interest Justification: By monitoring content performance, we identify and mitigate fraudulent interactions, ensuring that content consumption metrics reflect genuine user engagement. This enables our clients to make informed decisions about their content strategies.
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4. AUDIENCE THROUGH STATISTICS
   
   IAB TCF Purpose: "Understand audiences through statistics or combinations of data from different sources" (Purpose 9)
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   ‍Legitimate Interest Justification: We conduct market research to distinguish between legitimate user interactions and fraudulent activities. This process provides our clients with accurate audience insights, enhancing their ability to tailor offerings to genuine user needs.
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5. DEVELOP AND IMPROVE SERVICES
   
   IAB TCF Purpose: "Develop and improve services" (Purpose 10)
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   ‍Legitimate Interest Justification: Analyzing data on fraudulent activities allows us to improve our fraud detection algorithms and develop new features that better protect our clients' advertising efforts. Continuous product development ensures that we stay ahead of emerging fraud tactics, maintaining the efficacy of our services.
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6. SELECT CONTENT
   
   IAB TCF Purpose: "Use limited data to select content" (Purpose 11)
   
   ‍Legitimate Interest Justification: Our core operations involve identifying and mitigating fraudulent behaviors, ensuring the security and integrity of digital advertising ecosystems. Processing personal data is essential to detect, prevent, and respond to fraudulent activities, thereby protecting our clients and the broader digital advertising community.

Our organization processes personal data under the following Purposes:

We process personal data under the legitimate interest legal basis as defined by Article 6(1)(f) of the General Data Protection Regulation (“GDPR”).

1. We affirm that we safeguard the data we access and comply with the GDPR by:
   
   1.1 processing only the personal data that is strictly necessary to fulfill the specified Special Purpose(s) and and Legitimate Interest purposes.
   
   1.2 Providing clear, accessible information to individuals about our data processing activities, including their rights to access, correct, or delete their personal data.
   
   1.3 Regularly evaluating our processing activities to ensure they remain necessary, proportionate, and aligned with evolving regulatory requirements.
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2. We affirm our commitment to full compliance with the IAB TCF Policies and Specifications and to maintaining the highest standards of security and integrity in our data processing activities.
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3. By submitting this declaration, we confirm that our processing is lawful, necessary, and proportionate and that appropriate measures are in place to safeguard users’ rights and freedoms.

Deepankar Biswas
Chief Executive Officer
Botman Inc.