You can't put forth accumulation as a legitimate use of data, as in "it might help our eventual value when the company is sold, therefore we sleep it all up" an

You can't put forth accumulation as a legitimate use of data, as in "it might help our eventual value when the company is sold, therefore we sleep it all up" and neither would "we hand over the data, we get money, therefore it's our business" fly, but using PII in-house for running ads in a "registered, but not paying" service tier has all the trappings of legitimate interest.