GumGum

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.