Last updated: March 31, 2025

Introduction

The purpose of this notice is to define the terms and conditions for the processing of personal data by Azero Energy Solutions ("Azero") via its website and as part of the services it provides.

Data processing purposes and legal basis

Personal data shall be collected and processed for specific purposes and shall not be processed at a later date in a manner incompatible with those purposes, except in cases provided for by law.

Azero processes your personal data based on the following legal grounds:

• Contractual necessity: When processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract (setting up operational processes, providing requested services)

• Legal obligation: When processing is necessary for compliance with a legal obligation to which Azero is subject (particularly those which prevent money laundering and terrorist financing)

• Legitimate interests: When processing is necessary for the purposes of the legitimate interests pursued by Azero (improving our services, preventing fraud)

• Consent: When you have given clear consent for us to process your personal data for specific purposes (sending research updates to subscribers, marketing communications)

The data processed shall be relevant and limited to only what is necessary for the purposes for which it is being processed.

Data processed

Azero may need to process the following personal data:

• Personal information (first name, last name, age, nationality, occupation, etc.)

• Personal information issued by government agencies (identity documents, etc.)

• Contact information (address, telephone number, email)

• Bank information (account number)

• Login information

This data may be collected directly from you, or indirectly through one of our counterparties.

Azero does not process data related to ethnicity, sexual orientation, political affiliation, religious or philosophical beliefs, or union membership. It does not process genetic, biometric, or health-related data, nor does it process data related to criminal convictions and offenses, unless necessary and required or permitted by applicable legislation.

Cookie policy

What are cookies?

Cookies are small text files that are placed on your device when you visit our website. They allow us to recognize your device and store certain information about your preferences or past actions.

Types of cookies we use

• Essential cookies: Necessary for the website to function and cannot be switched off in our systems

• Performance cookies: Allow us to count visits and traffic sources so we can measure and improve the performance of our site

• Functional cookies: Enable the website to provide enhanced functionality and personalization

• Targeting cookies: May be set through our site by our advertising partners to build a profile of your interests

How to manage cookies

Most web browsers allow you to control cookies through their settings preferences. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Retention period

Data shall not be kept for longer than is required in order to provide the service requested and shall not exceed the limits imposed by the legislation in force. When Azero no longer needs your data, we will ensure that it is safely destroyed or anonymized in accordance with our internal policy.

Some data may be retained for an additional period of time so that we can manage claims and pre-litigation and/or litigation, so that we can meet our commercial, legal, and regulatory obligations, or so that we can respond to requests from authorized authorities.

The sharing and transfer of data outside of the European Union

We may share your personal data, either with our subprocessors, or with regulatory organizations with whom we are legally obliged to share information. In the course of managing our commercial relations, we may disclose and/or transfer personal data to countries outside the European Union. We will do this only in order to execute a contract which you have signed, to fulfill a legal obligation, to protect the public interest, or to defend Azero's legitimate interests.

Data security and privacy

Azero shall take necessary measures to ensure the data we collect is kept secure and confidential, that is, to ensure that only authorized associates tasked with processing data related to our services, will have access to your data and that their clearance is limited.

Procedure in case of a data breach

Azero shall inform the National Commission of Informatics and Liberties (CNIL) of any breach of personal data within at least 72 hours of having become aware of the breach. If a data breach is likely to pose a high risk to the rights and freedoms of a natural person, Azero shall inform the person concerned as soon as possible.

Your rights

Under the current legislation on data protection, you have the following rights:

• The right to access all of your personal data,

• The right to request that your data be updated, corrected, or deleted, subject to legitimate grounds,

• The right to oppose your data being processed for legitimate reasons as well as for prospecting without any justification,

• The right to request that your data be transferred, for data processing which is dependent on your consent or on the execution of a contract which has been, or will be, carried out.

• The right to ask that Azero limit the processing of your personal data,

• The right to withdraw your consent at any time (for all data processing subject to your consent),

• The right to lodge a complaint with a competent supervisory authority, namely that of the country in the European Economic Area where your habitual residence or your workplace is situated, or where the alleged violation of the regulations occurred (in France, the CNIL: https://www.cnil.fr/en/home).

You may exercise your rights at any time by contacting our Data Protection Officer:

• either by email at: info@azeroenergy.com

• or by mail at the following address: Azero Energy Solutions, Data Protection Officer, 106 rue Vieille du temple, 75003 Paris[Your Company Address]

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Policy. We encourage you to review this Privacy Policy frequently to stay informed about how we are protecting your information.