According to Article 9(1)(a) of Convention 108+, every individual shall have a right not to be subject to a decision significantly affecting him or her based solely on an automated processing of data without having his or her views taken into consideration. Profiling implemented by solely automated decision making can be considered as ‘significantly affecting individuals if it involves the risk of manipulation. Profiling for microtargeting in certain cases can be subject to this restriction. Data controllers shall take this right into account while using this type of advertising.