Privacy Policy EU

Website’s Privacy Policy

Last updated: 15 May 2024

This Privacy Policy is provided by AZIRA SAS (ex  Near intelligence, SAS) (“Azira France”, “We”), as data controller.

The website privacy policy applies to processing carried out via the Azira France website, https://azira.com/fr/ (hereinafter, the “Website”), and via commercial prospecting e-mails that you receive from Azira France.

For more information on how Azira France collects, uses and shares personal data of data subjects for processing related to Azira France's products and services, please see Azira France's Services Privacy Policy.

If you have any questions about this privacy policy, including any request to exercise your rights in relation to your personal data, please contact us at privacy@azira.com or contact our Data Protection Officer, Mr. Christoph Bauer at the following address:

• ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg, Germany; or
• Azira SAS, 4 RUE AUBER 75009 PARIS, FRANCE

1. Scope Of This Privacy Policy

This privacy policy describes how Azira France collects, uses and shares information received from you when you visit our Website (including through the use of cookies) or when you receive commercial prospecting emails from Azira France.

Our Website is primarily designed to provide information to our customers and partners, who are generally companies or professionals

2. Personal Data Collected Via The Website

Azira France collects information that identifies you or is associated with your device or browser, when (2.1.) you browse our Website, (2.2.) you contact us to find out more about our products and services or (2.3.) you receive commercial prospecting emails from Azira France.

2.1 Management of your browsing on our Website

When you browse our Website, Azira France collects information that identifies you or is associated with your device or browser (including through the use of cookies).

2.2 Contact form management

When you contact us via one of the contact forms on our Website, Azira France collects information that identifies you.

2.3 Commercial prospecting management

If you contact us via a contact form or if you are a customer of Azira France products or services, we may send you commercial prospecting emails. Emails received from Azira France may include a technology called a web beacon that informs Azira France whether you have received or opened the e- mail or clicked on a link in the e-mail.

If you no longer wish to receive commercial prospecting emails from us, you can update your e-mail preferences by using the "Unsubscribe" link in e-mails or by contacting us at Privacy@azira.com.

3. Purposes Of Processing Your Personal Data

Azira France processes your personal data to: 

• Enable you to use the Website;
• Improve your experience of using the Website;
• provide you with customer support and respond to your requests for information;
• Meet Azira France's interests; in certain circumstances, Azira France may disclose your personal data, in particular when Azira France considers in good faith that such data processing is necessary to: (i) protect, exercise, or defend the rights, privacy, safety, property of Azira France or those of its employees, agents and contractors (including the performance of our contracts and terms and conditions of use); (ii) protect the safety, privacy and security of users of the Website or the public; (iii) protect against fraud or for risk management purposes;
• Comply with legal obligations, or respond to requests from public and government authorities;
• Carry out commercial prospecting operations and to share your personal data with our trusted commercial partners, including other entities of the group of companies to which Azira France belongs, in order to enable them to send you commercial messages.

4. Lawful Basis For The Processing Of Your Personal Data

The processing purposes set out in Section 3 (a) to (d) and (f) of this policy are based on Azira France's legitimate interest in operating the Website, improving its services via the Website, responding to user requests and sending commercial prospecting emails to professionals.

The purpose of processing presented in Section 3 e) is based on compliance with applicable legal and regulatory obligations.

Some of the processing purposes set out in Section 3 (e.g. Section 3 b and 3 f) may be carried out based on your consent where required (e.g., when using cookies, which require your prior consent).

5. Cookies

When browsing the various pages of the Website, you may refuse or accept the deposit of cookies on your browser. The processing of personal data through the use of cookies on the Website is described in this policy.

The cookies used on the Website are detailed in the document “Cookies Policy - Azira France”.«Cookies Policy – Azira France ».

6. Recipients Of Personal Data

Within the framework of the processing purposes presented in Section 2 of the Privacy Policy, your data will be communicated internally within Azira France and, where applicable, within the Azira France Group, to the customer service department, the marketing/commerce department and the communications department. Azira France may also communicate your personal data to the following recipients:

• Other Azira France Group entities, as applicable (i.e., AZIRA US, AZIRA INDIA, AZIRA AUSTRALIA);
• Third-party service providers, subcontractors (i.e., IT service providers, service providers related to services on the Website - by way of illustration, and without this list being limitative, experts, consultants and lawyers, companies involved in potential mergers, demergers or other transformations);
• Competent national authorities: in order to comply with the law in force and also to any administrative or judicial authority that may request it or need access to it in the context of a possible control or dispute.
• Trusted business partners: subject to your consent.

7. Transfer Of Personal Data To Third Countries

Your personal data may be transferred to other Azira Group entities and to service providers acting on their behalf who are located in France and/or within the European Union.

Some of your data may be collected, accessed or stored outside your country of residence. You should be aware that data protection and security requirements differ from one location to another and may not offer the same level of protection as those in your home country. Nevertheless, Azira France has taken steps to ensure an adequate level of protection for your data, regardless of its location, for example by using standard data transfer clauses, or any other method approved by the European Commission (where data protection legislation is considered the most effective in the world) and/or National Data Protection Authorities. We also require our third-party partners to comply with applicable data transfer obligations, for example by contractual clauses, in respect of personal data they receive on our behalf.

8. Links To Third-party Websites, Applications And Services

The Website provides links to third-party websites, applications, including social networking pages, embedded social networking tools or "plug-ins", such as social networking tools. We do not own or control the privacy practices of these third parties, and they are not covered by this Website privacy policy.

If you decide to use any of the links available on the Website, you should review their privacy policies to learn more about their data practices. If you use these tools to share personal information or interact with these features, these companies may collect information about you and may use and share this information in accordance with your account settings, including sharing this information with us and the public.

9. Security Of Personal Information

The security of your information is important to us. Azira France has implemented reasonable security measures to protect the information in our custody, both during transmission and once received. This includes, but is not limited to, the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

10. Data Retention Period

Azira France retains your personal data for as long as is necessary for the performance of its purposes, as described in Section 3 above. 

Your data will be retained:

• For the time strictly necessary to use the Website;
• For commercial prospecting, 3 years from your last contact with Azira France;
• If Azira France is required to fulfil a legal obligation, your data will be processed for the time necessary to fulfil this obligation, as provided by law;
• Until your consent is withdrawn, if processing is based on your prior consent;
• For a period of 25 months from the date of collection for information collected via cookies.

11. Information For Minors

Azira France does not knowingly collect personal information from anyone under the age of 18 via the Website. If you are under 18, you should not use this website or provide us with any information about yourself. If we become aware that we have received personal information from anyone under the age of 18, we will use reasonable efforts to delete such information from our records immediately.

12. Your Rights

You have various rights under applicable data protection laws, including and depending on the situation, the right to:

• access your personal data (also known as a "data subject access request");
• correct any incomplete or inaccurate data we hold about you;
• ask us to erase or delete the personal data we hold about you;
• ask us to restrict our processing of your personal data;
• ask us to transfer your personal data to a third party;
• object to the way we use your personal data;
• withdraw your consent to the processing of your personal data; and
• provide us with instructions concerning the use and disclosure of your personal data (retention, deletion, transfer to a third party, etc.) after your death.

You can contact us to request the exercise of your rights at any time at privacy@azira.com. Please note that the exercise of these rights is not absolute and may be refused if the legal conditions are not met.

You also have the right to lodge a complaint with a supervisory authority such as the Commission nationale de l'informatique et des libertés (CNIL) in France.

We do not make any automated decisions that have legal effects or significantly affect you when processing your personal data.

13. Updating This Website Policy

We may update this policy from time to time and will use reasonable efforts to notify you of any significant changes. We encourage you to visit this page regularly for the latest information on our privacy practices.

Services Privacy Policy

Effective: 16 April 2024

We are Azira, SAS (“AZIRA FRANCE”).If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at privacy@azira.com or write to our Data Protection Officer, Prof. Dr. Christoph Bauer, CEO at:

• ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg, Germany; or
• Azira SAS, 4 RUE AUBER 75009 PARIS, FRANCE

1. When does this policy apply?

This policy describes how we collect and use information collected from third party publishers, advertisers, data partners, and third-party ad exchanges (Partners) about consumers for our mobile advertising, data intelligence analytics, data enrichment, visualization and measurement tools services (Services).

This policy also explains what personal data we collect about you, how we use your personal data, who is it shared with and what rights you have in relation to the same. 

Please read this policy to understand how we comply with our obligations under various privacy regulations, including the French Law No 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties and French Law No 2018-493 of 20 June 2018 on the protection of personal data and the General Data Protection Regulation (GDPR) applicable in the European Economic Area (EEA).

2. Are there any other policies I should be aware of?

• For the information on how we collect, use and share data collected on the English version of our website (https://azira.com/fr) (, please see our Website Privacy Policy.
• For more information on how we use cookies (and similar technologies) please see our Cookies Declaration Policy.

3. You use my personal data and for what purposes?

We may use your personal data for all or some of the following purposes:

• Targeted advertising services. We help our advertising and publishing customers provide more relevant advertising and content that is aligned with users' interests (“Targeting”). For example, we group users into audiences (“Targeting Segment”): sports fans, car enthusiasts, movie goers, travellers, and measure the effectiveness of campaigns. We also refine Targeting Segments to implement an additional Targeting Segment for users of social networks who have the same Mobile ID as that contained in the Targeting Segment (“Targeting Segment Bis”).
• Delivery of advertising services. We assist our Partners to provide you with personalized ads based on your preferences and your browsing habits (“Delivery”).
• Data intelligence services and reporting. We transform MAIDs, approximate geolocation information and the other data we collect (detailed above) into actionable insights for our customers. We provide customers with trend and statistical analyses, such as for identifying and optimizing trade areas and business locations, and for helping our customers make informed business decisions about consumer behaviour with trend and movement information. We provide actionable insights, patterns and commonalities to enable our customers to evaluate products and services they offer, such as enabling engagement with audiences and improving user experience of their apps and websites (“Reporting”).
• Improving our services, as a secondary purpose. We use your personal data to improve the way we work, improve our services (“Analytics”).

4. With Whom You Collect And Process My Data?

Your personal data are processed for the for above mentioned purposes by AZIRA FRANCE as data controller. 

For Targeting, AZIRA FRANCE is jointly determining the purpose and means of processing with Publishers, IAB Europe and Consent Management Platforms (CMP) acting as joint controllers within the meaning of Article 26 of GDPR.

For Delivery and Reporting, AZIRA FRANCE is jointly determining the purpose and means of processing with its clients acting as joint controllers within the meaning of Article 26 of GDPR.

You may ask to be provided with the essence of the arrangement between AZIRA FRANCE and the other joint controllers by contacting us at privacy@azira.com. 

5.What personal data do you collect?

When you use an app or visit a website that uses advertising software placed by us or our Partners, we and our Partners may collect your mobile advertising identifier (MAID) from your device, internet protocol (IP) address, cookies, location data (including latitude data / longitude data), browser type, device type, connection type, carrier, time stamp, operating system and version, language preference, environment, SSP, your consent, the names of other mobile apps you use and how you browse the app or website.

6. Where do you receive my personal data from?

We receive data from our Partners' apps and websites, including:

• For Targeting: your personal data are collected via a Consent Management Platform (CMP) implemented on a publisher’s (owners and sellers of digital advertising space) website, APIs or mobile app. personal data may also be provided by AZIRA FRANCE’s Partners. We also collect data from other trusted third-party providers and publicly available sources such as social media sites, census data providers and certain public directories.
• For Delivery: your personal data is the Targeting Segment and the Targeting Segment Bis implemented by AZIRA FRANCE during the Targeting purpose. 
• For Reporting: your Personal Data is the Targeting Segment, the Targeting Segment Bis but also the Personal Data provided by real-time bidders providers or other Partners concerning the performance of the delivery campaigns.
• For Analytics: your personal data corresponds to the personal data collected in the three above mentioned purposes (Targeting, Delivery and Reporting).

7.What lawful basis do you rely on for using my personal data?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

8. How is my personal data protected?

• Where feasible, we shall encrypt your personal data where it is in transit or at rest. By default, AZIRA FRANCE database system is encrypted at rest.
• We replace MAIDs with hashed identifiers, aggregate our other data points and cluster location data so that it is pseudonymised.
• For operational purposes, location precision is reduced, and data is aggregated, along with strict retention delays.
• We retain MAIDs internally in their original form to cater to our customers' request for targeted advertising, measurement and matching. This data is stored separately from the pseudonymised data.
• We do not seek to create analytics based on sensitive personal information (for example, religion or credit worthiness).
• Data used to Targeting Segment is pseudonymised. We may assign our own "Azira ID" to replace your MAID in our internal systems for your browser, computer or mobile device when we serve an advertisement to it or we identify it on a Partners' website or app.
• We require all our customers that we share user data with to comply with applicable data protection laws. We also do not permit any customers to use our services for (a) employment, credit or health care eligibility checks; (b) insurance eligibility, underwriting, or pricing services; or (c) unlawful tracking or surveillance of individuals.
• We follow a practice of “Least Privilege Access”. This principle is the practice of limiting access rights for users to the bare minimum permissions needed to perform required job functions, and thus differs from job-to-job and employee-to-employee.
• Data is filtered and removed to ensure that fraudulent data falsely attributed to data subjects is removed and that GDPR rights are observed. Data retention policies ensure that only adequate data is retained and for a limited time. Location accuracy is reduced at the end.
• Access to raw data is limited by role and business need. This data is only used in the context of building audiences for advertising, after being aggregated.
• We have executed a Data Processing Agreements (DPA) with all our data processors to ensure that they all implement sufficient technical and organizational measure and comply with the highest standards on IT security.

9. Who do you share my personal data with?

• Customers, for the provision of our Services. Where our customers need MAIDs for the purposes of serving targeted advertising, measurement and matching, we will provide MAIDs in their original form for this purpose.
• Business partners, suppliers and subcontractors for the performance of the contract we enter into with them, for example for website hosting and email delivery services, running campaigns or to perform campaigns analytics. Third parties that support us in targeted advertising include: Google Cloud, Google Workspace, Meta, SSP, Adsquare, Bidswitch, KairosFire or E RETAIL DEVELOPMENT.
• Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
• Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer. If AZIRA FRANCE is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.

10. Where do you store and transfer my personal data?

We store your data on our servers in France and within the EEA .

For individuals in the EEA, we may need to transfer your personal data outside of the EEA towards our data processors to provide our products and services.

Whenever we transfer your personal information outside of the EEA, we ensure it receives additional protection as required by law, including by entering into approved standard contractual clauses. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at privacy@azira.com for more information on this.

11. How long do you keep my personal data for?

We will only retain your personal data for as long as we need it for the purposes it was collected, unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.

• For Targeting: your Personal Data is stored as raw stored for 5 days in AZIRA FRANCE’s database then minimized and aggregated. It is then stored as aggregated data for 90 days. After the retention period define herein, raw data is definitely deleted from AZIRA FRANCE’s databases.
• For Delivery: your Personal Data is stored for 180 days in AZIRA FRANCE’s database. At this level, AZIRA FRANCE stores your Personal Data after minimizing and aggregating. After the retention period define herein, your Personal Data is definitely deleted from AZIRA FRANCE’s databases.
• For Reporting: your Personal Data is stored for 180 days in AZIRA FRANCE’s database. At this level, AZIRA FRANCE stores delivery data after minimizing and aggregating to serve the Reporting purpose. After the retention period define herein, your Personal Data is definitely deleted from AZIRA FRANCE’s databases.
• For Analytics: your Personal Data is stored as raw stored for 5, 90 or 180 days depending on the level of granularity and minimization of Personal Data in AZIRA FRANCE’s database. After the retention period define herein, raw data is definitely deleted from AZIRA FRANCE’s databases.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work, improve our services.

12. Does AZIRA FRANCE collect personal data relating to children?

AZIRA FRANCE does not knowingly collect personal information from anyone under the age of 18 through our Services and our Services are not targeted at children.

If you are below the age of 18 years, you must not use our Services or provide any information about you to our Partners and to us.

If we are made aware that we have received personal information from someone under 18 years of age, we will use reasonable efforts to immediately delete that information from our records.

13. What are my rights under data protection law?

You have various other rights under applicable data protection laws, including the right to:

• access your personal data (also known as a “subject access request”);
• correct incomplete or inaccurate data we hold about you;
• ask us to erase or delete the personal data we hold about you;
• ask us to restrict our handling of your personal data;
• opt-out of our sharing or selling your personal data;
• opt-in to the processing of any sensitive information we hold about you;
• ask us to transfer your personal data to a third party;
• object to how we are using your personal data; and
• withdraw your consent to us handling your personal data; and
• provide us with instructions concerning the use and disclosure of your personal data (retention, erasure, third party transfer, etc.) after your death.

You can contact us to ask about exercising your rights at any time at privacy@azira.com. Please keep in mind that privacy law is balanced with other important legal requirements, and these rights will not always be available to you all of the time.

You also have a right to lodge a complaint against a supervisory authority such as the Commission Nationale de l’Informatique et des Libertés, “CNIL” in France

We do not carry out any automated decision-making that produces legal effects or similarly significantly affects you.

14. Will there be changes to this policy?

We may update this policy from time to time and will use reasonable efforts to notify you of any significant changes. We encourage you to revisit this page for the latest information on our privacy practices.

Cookies Policy

Last updated: 16 May 2024

This document applies to Azira website, www.azira.com (hereinafter, the “Website”) and provides information on the cookies used by Azira France for the Website.

For more information about how Azira France collects, uses and shares your data when you browse the Website, please visit Azira's Website Privacy Policy.

1. Current Status Of Your Consent To Cookies

2. Description Of Cookies Used On The Website

Our Website uses various cookies, the full list of which is given below. These cookies are either (i) essential or (ii) non-essential.

A cookie is a text file containing an identification number which, when using the Website, is transmitted to the user's computer along with the other data requested and stored there. The file is stored for future access and is used to authenticate the user. As cookies are simple files and not executable programs, they present no danger to the computer. You may choose to disable cookies, which may limit your use of certain features or functions of our website or service. For more information on cookies, please visit https://www.allaboutcookies.org/.

2.1 Strictly necessary cookies

We use essential cookies to distinguish you from other users of our Website and app. This helps us to provide you with a good experience when using our websites and apps. We are allowed to set these cookies without your prior consent, but you can block all cookies, including essential cookies, by changing your browser settings.

Please note that if you block all cookies, you may not be able to view or access all parts of our Website.

2.2 Non-essential cookies

The other types of cookies we use are non-essential cookies. We use them to help us make improvements to our products and services.

We have listed the non-essential cookies that we may use and that we may allow our partners to use in the table below.

When you give your consent to Azira France and only in this circumstance, we install these cookies on your terminal.

Azira France uses Google Analytics, a web analysis service from Google, Inc. Google Analytics uses cookies that are stored on your computer to facilitate an analysis of your use of the Website. The information generated by these cookies, such as the time, location and frequency of your visits to our Website, including your IP address, is transferred to and stored by Google in the United States.

3. Cookie Duration

Cookies are stored on your device until you withdraw your consent or for a maximum period of 13 months from the date of your consent.

Your choice regarding cookies is valid for 6 months. At the end of this period, we may ask you again to confirm your choices regarding the cookies used on the Website.