Legitimate Interest Assessments

Effective Date: 1st January 2025

At dkode Limited (dkode), we are committed to ensuring that our data processing activities comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws. As part of this commitment, we conduct Legitimate Interest Assessments (LIAs) to ensure that our use of personal data is lawful, fair, and transparent. Below, we outline our approach to conducting LIAs and how they align with our mission to empower decision-makers through innovative information experiences.

1. What is a Legitimate Interest Assessment?

A Legitimate Interest Assessment (LIA) is a structured process used to determine whether the processing of personal data can be justified under the “legitimate interests” legal basis as defined in Article 6(1)(f) of the GDPR. This legal basis allows organizations like dkode Limited to process personal data when it is necessary for their legitimate interests, provided that such processing does not override the rights and freedoms of individuals.

Our LIAs are designed to balance our business needs with the privacy rights of individuals. By conducting these assessments, we ensure that our data processing activities are ethical, transparent, and aligned with both regulatory requirements and industry best practices.

2. When Do We Conduct an LIA?

At dkode Limited, we conduct an LIA whenever we rely on legitimate interests as the legal basis for processing personal data. Examples include:

• Improving Services: Analyzing user interactions on dkode.co to enhance website functionality and user experience.

• Marketing Activities: Sending relevant communications about our services or projects to individuals who have expressed interest in dkode Limited.

• Fraud Prevention: Detecting and preventing fraudulent activities or security threats on our platforms.

• Research and Development: Using anonymized or pseudonymized data for research purposes aimed at improving digital transformation strategies.

3. The Three-Part Test for Legitimate Interests

To ensure compliance with GDPR requirements, each LIA conducted by dkode Limited follows a rigorous three-part test:

(a) Purpose Test

• We identify the specific purpose(s) for which personal data is being processed.

• Example: To analyze website traffic patterns on dkode.co in order to improve navigation and accessibility.

(b) Necessity Test

• We evaluate whether the processing is necessary to achieve the identified purpose(s).

• Example: Collecting anonymized IP addresses may be necessary for understanding regional trends in website usage without compromising individual privacy.

(c) Balancing Test

• We assess whether the individual’s rights and freedoms outweigh our legitimate interests.

• Example: Ensuring that users have access to clear opt-out mechanisms if they do not wish their browsing behaviour to be analysed.

If any part of this test indicates that the individual’s rights outweigh our legitimate interests, we will either cease processing or seek an alternative legal basis for doing so.

4. Safeguards Implemented by dkode Limited

To protect individual rights while pursuing legitimate interests, dkode Limited implements robust safeguards:

• Transparency: Clear communication about how personal data is collected, used, stored, and shared through privacy notices available on dkode.co.

• Data Minimization: Only collecting personal data that is strictly necessary for achieving specific purposes.

• Anonymization & Pseudonymization: Where possible, transforming personal data into formats that reduce identifiability.

• Opt-Out Options: Providing individuals with simple ways to object to certain types of processing based on legitimate interests.

• Regular Reviews: Periodically reviewing LIAs to ensure continued compliance with evolving regulations and best practices.

5. Your Rights as a Data Subject

Under GDPR, individuals have several rights regarding their personal data processed under legitimate interests. These include:

• The right to object: You can object to your personal data being processed based on legitimate interests at any time by contacting us at privacy@dkode.co.

• The right of access: You can request details about what personal data we hold about you and how it is being used.

• The right to erasure: In certain circumstances, you may request that your personal data be deleted from our systems.

For more information about your rights or how we handle your personal data at dkode Limited, please refer to our Privacy Policy available on dkode.co.

6. Contact Us

If you have any questions about this Legitimate Interest Assessment page or would like further details about how your personal data is processed under this legal basis, please contact us at: