Legitimate Interest Claim
Last Updated: October 12, 2026
This page sets out the legitimate interests Tickle relies on as a lawful basis for processing personal data under Article 6(1)(f) of the UK and EU General Data Protection Regulation, in the context of our registration with the IAB Europe Transparency and Consent Framework (TCF) v2.2.
Tickle relies on legitimate interest for two TCF Special Purposes only. All other processing is carried out on the basis of consent. Full details of our data handling are set out in our Privacy Policy at https://jointickle.com/privacy-policy.
Special Purpose 1: Ensure security, prevent and detect fraud, and fix errors
The interest pursued
Tickle operates infrastructure that allows consumers to save digital advertising to their mobile wallet. We process a limited set of technical data to keep that infrastructure secure, to detect and prevent fraudulent or automated activity, and to identify and correct technical faults.
Data processed
IP address, device characteristics, device identifiers, and technical metadata including timestamp, operating system and browser type.
Why the processing is necessary
Without this processing we cannot distinguish genuine consumer activity from automated or fraudulent traffic, cannot protect the service against abuse, and cannot diagnose faults that would otherwise prevent consumers from receiving the wallet pass they have asked for. There is no less intrusive way to achieve this.
Balancing assessment
The data processed is limited to what is technically necessary and is not used to build profiles of individuals, to personalise advertising, or to make decisions about individuals. Security and fraud prevention is processing that data subjects would reasonably expect of any service operating online, and it protects consumers as much as it protects Tickle. Data is retained for no longer than is necessary and is subject to the retention periods set out in our Privacy Policy. On that basis we consider that the interests and fundamental rights of data subjects do not override the legitimate interests pursued.
Special Purpose 2: Deliver and present advertising and content
The interest pursued
Tickle processes technical data in order to deliver an advertisement to a consumer's device, render it correctly, and generate the wallet pass when a consumer chooses to save it.
Data processed
IP address, device characteristics, device identifiers, non-precise location data derived from IP address at city level, and technical metadata including source URL, timestamp, operating system and browser type.
Why the processing is necessary
An advertisement cannot be delivered to a device, nor rendered in a format that device can display, without processing basic technical information about the request. Where a consumer chooses to save the advertisement, a device identifier is required to generate and deliver the wallet pass to that consumer and to prevent duplicate passes being issued.
Balancing assessment
This is the minimum processing required to perform the function the consumer is asking for. We do not use this data to create profiles for personalised advertising, to select advertising based on user profiles, or to track consumers across unrelated services. Location data is resolved only to city level and is never processed at a more granular precision. The processing is limited, expected, and necessary to deliver the service. We consider that the interests and fundamental rights of data subjects do not override the legitimate interests pursued.
What Tickle does not do under legitimate interest
Tickle does not rely on legitimate interest for creating or using profiles for personalised advertising or content, for audience statistics, or for product development. We do not process precise geolocation data. We do not combine data from other sources or link data across devices.
Where a consumer saves an advertisement to their mobile wallet, that save is an explicit, consumer-initiated action, and the processing that follows is carried out on the basis of consent.
Your rights
Data subjects have the right to object to processing carried out on the basis of legitimate interest. To exercise that right, or any other right under the GDPR, contact privacy@JoinTickle.com. Our full Privacy Policy, including details of all data subject rights and how to exercise them, is available at https://jointickle.com/privacy-policy.
Tickle Global Ltd
167-169 Great Portland Street, London, W1W 5PF, United Kingdom
privacy@JoinTickle.com