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GumGum is a United States contextual advertising platform that analyses page content to deliver relevant ads through its Verity technology. It serves display, in-image, and video advertising and can run contextual, cookieless campaigns. However, ad delivery and measurement may still set advertising and measurement identifiers that require consent in the European Union.
GumGum is a contextual advertising platform based in the United States that analyses the content of a page to decide which ads are relevant. Its Verity technology reads text and imagery to understand context without depending on personal profiles. It serves display, in image, and video advertising across publisher inventory.
GumGum can run in a contextual, cookieless mode that targets based on page content rather than personal identifiers. However, ad delivery and measurement may still set advertising and measurement cookies, including an advertising identifier, a cookie sync cookie, and a frequency or measurement cookie. When those identifiers are used they are personal data under the GDPR and require consent.
Purely contextual targeting that does not read or store information on the device can often operate without consent, but any advertising or measurement cookie triggers Article 5(3) of the ePrivacy Directive and requires prior consent. The associated processing then needs a GDPR legal basis, which for advertising is consent under Article 6(1)(a). The distinction between the contextual layer and the identifier based layer is central to compliance.
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Where identifiers are used, consent should be collected before any cookie is set and communicated through a consent management platform that supports the IAB Europe Transparency and Consent Framework. The TCF signal tells GumGum and its partners what the user allowed. If consent is refused, GumGum can fall back to its contextual, cookieless mode where supported.
GumGum processes advertising and measurement data in the United States and shares it with partners. Where personal data leaves the European Economic Area, transfers rely on Standard Contractual Clauses supported by a transfer impact assessment. Contextual only campaigns reduce the volume of personal data subject to these transfers.
Decide whether you will run GumGum in contextual only or identifier based mode, and gate any advertising cookies behind consent through a TCF compatible platform. Document the cookies in your cookie policy, keep records of consent, and offer an easy way to withdraw it. Confirm the transfer safeguards and review the configuration so the live behaviour matches your disclosures.
Websites using GumGum must obtain user consent under GDPR regulations.
DPIA considerations
GumGum is a moderate risk platform because its contextual targeting can reduce reliance on personal data, yet ad delivery and measurement may still use identifiers. Key considerations are (1) the mode of operation, since contextual only campaigns process little personal data while identifier based delivery profiles users; (2) the legal basis, which must be consent collected before any advertising cookie is set and signalled through the IAB Europe TCF; (3) transparency, clearly explaining the contextual and identifier based layers to users; (4) international transfers, since advertising and measurement data is processed in the United States under Standard Contractual Clauses and a transfer impact assessment; and (5) data subject rights, including easy withdrawal of consent and a contextual fallback when consent is refused. The assessment should document which mode is active and confirm that cookies do not fire before consent.
Sample consent text
We use GumGum advertising cookies to deliver and measure ads, which may share identifiers with partners in the United States. Click Accept to allow this or Reject to receive contextual ads only.
Third-party domains contacted
gumgum.comg2.gumgum.comgacm.gumgum.comCookies placed
| Name | Type | Duration | Purpose |
|---|---|---|---|
| gg_uid | Advertising | 1 year | Stores a unique advertising identifier used to recognise the browser when identifier based ads are served. |
| gg_sync | Advertising | 90 days | Synchronises the advertising identifier with partners so bids and ads can be matched to the user. |
| gg_meas | Advertising | 90 days | Measures ad impressions and applies frequency capping to report performance and limit repetition. |
GumGum places tracking cookies for advertising — comply with GDPR using FlowConsent.
In its contextual mode GumGum can run without cookies, targeting based on page content. When ads are delivered and measured it may set advertising and measurement cookies, typically an advertising identifier, a cookie sync cookie, and a frequency or measurement cookie. These identifier cookies are non essential and require consent in the European Union.
It depends on the mode. Purely contextual targeting that does not store or read information on the device can often run without consent, but as soon as an advertising or measurement cookie is used, Article 5(3) of the ePrivacy Directive requires prior consent. Where identifiers are involved, consent is also the appropriate GDPR legal basis.
For identifier based advertising the legal basis is consent under Article 6(1)(a) of the GDPR, with prior consent required by Article 5(3) of the ePrivacy Directive and signalled through the IAB Europe TCF. Purely contextual analysis that does not process personal data may not need a consent based legal basis. The appropriate basis therefore depends on whether identifiers are used.
Yes. GumGum processes advertising and measurement data in the United States and shares it with partners. Where personal data leaves the European Economic Area, transfers rely on Standard Contractual Clauses supported by a transfer impact assessment. Running contextual only campaigns reduces the volume of personal data subject to these transfers.
A data protection impact assessment is advisable when GumGum is used in its identifier based mode, since that involves profiling for advertising. For purely contextual, cookieless campaigns the risk is lower and a full assessment may not be required. The assessment should record which mode is active and confirm that no cookies fire before consent.
Decide whether to run GumGum in contextual only or identifier based mode, and block any advertising cookies until the user consents through a TCF compatible consent management platform. Document the cookies in your cookie policy, keep records of consent, and offer an easy way to withdraw it. Use the contextual fallback when consent is refused and confirm the transfer safeguards.
Alternatives include other contextual advertising providers and traditional programmatic platforms, as well as in house contextual targeting where feasible. Contextual, cookieless solutions like GumGum Verity are themselves an alternative to identifier heavy advertising. The right choice depends on your reliance on personal data and your consent strategy.
Explain that GumGum can run contextually without cookies but may set advertising and measurement cookies when identifiers are used. List those cookies by name, type, duration, and purpose, and note that data may be processed in the United States under Standard Contractual Clauses. Tell users how to manage or withdraw consent and that refusal leads to contextual ads only.