{"page":"/blog/contextual-advertising-personal-data-gdpr","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","A context-only request that carries a full URL, an IP address, a user-agent string or a timestamp processes personal data. Where a script on the device assembles it, Article 5(3) applies, and advertising is not strictly necessary for the service. Without a recorded choice, no request is sent.","Article 4(1) and Recital 30; Article 5(3); the Board's guidelines","Requests wait for a choice; page context that reveals sensitive topics is removed"],["A permissive reading","A request limited to a page category and coarse data, sent from a server without reading the device, is outside Article 5(3). Where the recipient has no means reasonably likely to identify anyone, the data is not personal data for that recipient. Remaining processing can rest on legitimate interests.","The wording of Article 5(3); the Court's 2025 ruling ; Article 6(1)(f)","A reduced request is sent from the server when no choice is recorded"]],"sourceUrls":[[],[]]}