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@trainline_eu @FabianRODES @edasfr @yverry As stated by WP29, analytics and product improvement can never be a legitimate interest. And so, you’re not GDPR compliant, because you **need** consent before collecting and using such data.Permalink On twitter.com
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Mood +5 🙂
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@trainline_eu @FabianRODES @edasfr @yverry See ec.europa.eu/justice/article-29/documentation/opinion-recommendation/files/2014/wp217_en.pdf page 25 & 26Permalink On twitter.com
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Mood 0
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@trainline_eu @FabianRODES @edasfr @yverry Analytics & product improvement is (business) legitimate interest for data controller, but can't be (privacy) legitimate interest and can't rely on 7(f) of GDPR.Permalink On twitter.com
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Mood +4 🙂
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@trainline_eu @FabianRODES @edasfr @yverry If it's really your (business) legitimate interest, you have to find another RGPD rule to collect and use data, for example by consent collection.On twitter.com
Mood +3 🙂
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@trainline_eu @FabianRODES @edasfr @yverry And in all cases, even if you rely on 7(f), you have to ensure privacy for processed data, and never ever Facebook was a trustable third party. And worse since 1 year and all Facebook privacy issues.Permalink On twitter.com
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Mood -2 🙁
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@trainline_eu @FabianRODES @edasfr @yverry And in all cases, even if you rely on 7(f), you need a "workable mechanism to allow objecting to such a processing" (14(b) of GDPR)Permalink On twitter.com
Mood +1 🙂