{"page":"/blog/bank-transaction-data-advertising-gdpr-psd2","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Reading","What it holds","What it relies on","What it means for a design"],"rows":[["A cautious reading","Advertising based on transactions can exceed a customer’s expectations for banking. This reading looks to consent and a separate special-category condition where relevant, and excludes silent-party and restricted payment-service data.","GDPR Articles 5, 6 and 9, EDPB Guidelines 06/2020, and {V07b:C-252/21, paras. 105–126}","The design separates advertising consent and strips data connected with silent parties and sensitive merchant categories."],["A permissive reading","Limited own-channel marketing of the bank’s products can rely on legitimate interests after assessing the balance and giving effect to objections. This reading distinguishes that use from third-party or device-based advertising.","GDPR Articles 6(1)(f), 21 and Recital 47 and the specific processing facts","The design keeps own-channel signals limited and separates any shared data or device operations."]],"sourceUrls":[["https://eur-lex.europa.eu/eli/reg/2016/679/oj","https://www.edpb.europa.eu/system/files/documents/files/file1/edpb_guidelines_202006_psd2_afterpublicconsultation_en.pdf"],["https://eur-lex.europa.eu/eli/reg/2016/679/oj"]]}