ESAI Energy, LLC “ESAI” processes information that identifies individuals or is identifiable to individuals, which is referred to as “Personal Information.” ESAI’s processing of Personal Information is governed by this Privacy Policy as well as the laws and regulations that govern our processing of Personal Information, which are referred to as “Data Privacy Laws.” This Policy does not apply to ESAI’s processing of Personal Information for employment, or to the processing of Personal Information that is otherwise excluded from Data Privacy Laws.

If you have any questions about this Policy or how ESAI processes Personal Information, please contact one of our Privacy Officers as follows.

Name: Linda Vojkovsky

Address: 300 Ballardvale Street, Suite 114 Andover MA 01810

Phone number: 978-482-0900

Email address: lvojkovsky@esai.com

Personal Information

ESAI is an energy market intelligence and consulting firm that provides data, forecasts, and

strategic analysis relating to global oil, fuels, refining, and emerging energy market, which are referred to as “Services.” ESAI provides the Services to businesses, governmental entities, and other organizations, which are referred to as “Clients.”

In the course of providing Services and conducting Operations (as that term is defined below), we interact with a broad range of individuals, including the following: employees of Clients; owners, shareholders, members, managers, directors, officers, employees, associates, contractors, customers, vendors, service providers, agents, representatives, insurers, attorneys, and affiliates of Clients; individuals who attend ESAI events, use the ESAI website and other ESAI technology systems, receive information from ESAI, and otherwise interact with employees and other representatives of ESAI; and ESAI vendors, service providers, contractors, agents and representatives. All individuals with whom we interact in the course of providing Services or conducting Operations are referred to as “Individuals.”

In the course of providing Services and conducting Operations, ESAI processes a limited category of Personal Information. The following lists some common categories, including Personal Information that we have processed in the preceding 12 months.

• Name and Contact Information. Current and previous first, middle, and last names, signature, residential and business addresses, phone numbers, email, and other personal identifiers.

• Technological Information. Internet Protocol or IP address, Media Access Control or MAC address, browsing activity, use of ESAI’s website and technology systems, and other technological information.

• Security Information. Information relating to access to and use of ESAI’s physical facilities and technology systems, and other security information.

• Billing Information. Information about the Services we provide to Clients, the fees we charge for those Services, our invoicing for Services, and other billing information.

• Client Information. Information that we process related to or in the course of providing Services to or for a Client.

• Operations Information. Information that ESAI processes to conduct our own operations, including administration, accounting, finance, marketing, technology, cybersecurity, privacy, management of vendors and services providers, human resources, records management, facilities management, and other types of operations, which are referred to as “Operations.”

We collect Personal Information in connection with our Services from various sources, including: (1) when you fill out a form on our website, apply for or inquire about our Services; (2) when you attend any events hosted by ESAI or otherwise interact with us; (3) visitors to our website or offices; and (4) others.

If you provide Personal Information to ESAI about any Individual other than yourself, we ask and expect that you have the authority to do so or consent to do so from that Individual.

Sensitive Personal Information and Information about Children

Except as otherwise stated in this Policy, we do not intentionally collect Personal Information that is sensitive, including personally identifiable information or PII under Data Privacy Laws, protected health information or PHI and other health information, information about minors and children, and information about race, ethnicity, national origin, citizenship, immigration status, gender and sexual orientation and identification, religion or religious belief, political affiliation, union membership, criminal and credit matters, biometric information, specific geolocation, financial information, and children, which is referred to as “Sensitive Personal Information.” For purposes of this Policy, Sensitive Personal Information is a sub-category of Personal Information. If we receive Sensitive Personal Information, whether inadvertently or otherwise, we reserve the right to delete such information in our sole discretion and in accordance with applicable law.

Purposes and Bases for Processing Personal Information

ESAI may process Personal Information for a broad range of purposes and bases. While it would be imprudent to attempt to list every such purpose or basis, the following lists some of the more common purposes and bases for which we process Personal Information.

• Consent and Direction. Based on consent and direction given to us by Clients, Individuals, and third parties about whom Personal Information pertains or who otherwise have authority or consent to provide such consent or direction.

• Provide Services. Activities related to providing Services to or for Clients, and improving the Services that we offer and provide.

• Business Relationships. Interact with Clients, Individuals, and third parties with respect to ESAI’s or their business activities and interests.

• Compliance, safety, claims, and website. To comply with applicable laws and regulations, including Data Privacy Laws; to ensure safety and protect ESAI, our personnel, Clients, Individuals, third parties, and ESAI’s physical facilities and technology systems; to establish, enforce, and exercise our rights and defend against claims; and to monitor, develop and maintain the operation, security and integrity of our website and technology systems.
• Operations. Activities related to ESAI’s Operations.
  

Disclosure of Personal Information

ESAI may disclose Personal Information under the following circumstances.

• Consent and Direction. Based on consent and direction given to us by Clients, Individuals and third parties about whom the Personal Information pertains or who otherwise have authority or consent to provide such consent or direction.

• Provide Services. As necessary or appropriate to provide Services to or for Clients.

• Agents of Clients, Individuals and ESAI. To owners, shareholders, members, managers, directors, officers, employees, associates, contractors, customers, vendors, service providers, agents, representatives, insurers, and attorneys of ESAI, Clients or Individuals as necessary or appropriate to provide Services to Clients or support our Operations.

• Compliance, safety, claims and legal process. To comply with applicable laws and regulations, including Data Privacy Laws; to ensure safety and protect ESAI, our personnel, Clients, Individuals, third parties, and ESAI’s physical facilities and technology systems; to establish, enforce, and exercise our rights and defend against claims; and to comply with a valid subpoena or other legal process or lawful request by governmental, regulatory, and law enforcement authorities.
• Business Transfers. In anticipation of or the course of an acquisition, merger, consolidation, restructuring, sale of ownership interests, assets or both, or other such corporate change.

Privacy Rights

Depending on the Personal Information ESAI processes about an Individual, and the manner in which we process such Personal Information, an Individual may have the following rights with respect to our processing of Personal Information about that Individual.

• Scope of Processing. Disclosure about how we process Personal Information, the categories of Personal Information we process, and the categories of sources from which such Personal Information was obtained.

• Access. Access or receipt of a copy of Personal Information, including (if appropriate) in a portable, machine-readable, and commonly used format.

• Correction. Rectify or correct inaccurate or incomplete Personal Information.

• Deletion. Deletion or erasure of Personal Information.

• Withdraw Consent. Withdraw consent if we rely on consent as a basis for processing Personal Information, provided that such withdrawal will not affect the lawfulness of our processing of Personal Information before such withdrawal or the continued processing of it after withdrawal for a purpose or basis other than consent.
  
  
• Selling, Profiling, and Targeted Advertising. Disclosure about whether ESAI sells, shares, trades, exchanges, or brokers Personal Information with or to a third party for the purpose of that or any other third party using the Personal Information to market on their own behalf, which is referred to as “Selling”; disclosure about whether ESAI uses automated decision making to evaluate, analyze or predict personal aspects related to an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, which is referred to as “Profiling.”; disclosure about whether ESAI targets advertising to individuals based on their activities on unaffiliated third party websites, which is referred to as “Targeted Advertising”; and to object or opt-out of such Selling, Profiling and Targeted Advertising.

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our website. ESAI will respond to all complete requests within 45 days, subject to extension of that period. Also, there may be a delay in processing a request while we verify that the request is valid and originates from a person authorized to make it.

There may be valid reasons that require or permit us to decline to honor a request, in whole or in part, including legal and regulatory requirements that we retain and process certain information. Also, honoring certain requests may limit or prevent us from providing Services to the Individual about whom the request is made. In those situations, we will notify you in writing within 45 days, subject to extension of that period. You may also contact one of our Privacy Officers for information about and help with those situations.

ESAI will not discriminate against an Individual for exercising these rights or any other rights under Data Privacy Laws, including by not denying Services to that Individual, not providing a different level or quality of Services to that Individual, and not suggesting that Individual will receive a different level or quality of Services.

Selling, Profiling, and Targeted Advertising

ESAI does not engage in Selling, Profiling, or Targeted Advertising, except with respect to tracking technologies as discussed below.

Use of Artificial Intelligence

ESAI uses artificial intelligence or AI to process Personal Information and for other purposes, including for the purposes and bases described above and with respect to our Services and Operations. While it would be imprudent to attempt to list every such use of AI, particularly since it is an evolving technology, the following lists some ways that ESAI uses AI to process Personal Information and for other purposes: organize, summarize, analyze, recognize patterns, and identify specific aspects of information; create records, documents, text, images, communications, and similar content generated by AI based on information and prompts input into AI; conduct research; use notetakers and transcribers for meetings, video conferences, and ESAI events; and perform other discrete aspects of our Services and Operations. As a result, the Services provided by ESAI and the information generated by ESAI may be based, in whole or in part, on output from AI.

Video and Audio Recording

ESAI uses technology to facilitate meetings, video conferences, and other ESAI events, including technology that captures video, images, and audio, such as recording devices and AI notetakers and transcribers. By participating in ESAI meetings, video conferences, and events, you consent to ESAI’s recording and processing of video, images, and audio collected during such meetings, video conferences, and events.

Website, Cookies, Tracking Technology, and Third Party Tools

ESAI may collect and generate information about you when you interact with our website, which may include name and contact information (as described above), information about the device you use to interact with our website, and information about your interaction with our website (such as content you view, features you access, sites you view immediately before and after you access our website, content you view on our website, search terms you use on our website, and content in which you have indicated interest).

When you visit ESAI’s website, we may place a cookie (a text file containing a randomly assigned number) or a similar technology on your device so we have the ability to customize the look and feel of the website for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website. Using cookies, we may also collect other information about your use of the website, including your Internet Protocol or IP address, username, session, browser, web pages you view and referring web pages, when you access the website, and general online behavior for performance and marketing purposes.

ESAI may use third-party analytics tracking technologies and tools to collect information about how you use our website, such as the frequency of visits, pages viewed, traffic data, location, referring and exit pages, and error information. These tools may also collect device-specific data, including your IP address, operating system, browser type, and Internet connection details. These tools examine website activities to prepare usage reports, and this information helps us improve our website and enhance user experience. Tracking information will be shared with the third-party analytics provider, which may use that information for its own purposes, potentially including marketing or advertising. While the tracking information we collect through such tools is not sufficient on its own for ESAI to identify you, the third-party analytics provider may be able to combine it with other data it has to identify you.

If you would like to limit the ability of cookies or tracking technologies and tools to track your activity on our website, you can either configure your preferences for cookie settings on our website, or disable cookies in your Internet browser settings, although doing so may impact the performance and effectiveness of our website or other websites.

ESAI may use third party tools to provide Services and for other purposes, and our website may contain links to third party websites. We have no control over the policies and practices of such third-party tools and websites. Please review the applicable policies of such third parties for information regarding their processing of Personal Information.

Duration of Retention

Because the Services that ESAI provides to Client’s vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Services that ESAI provides to particular Client’s, the duration and depth of ESAI’s relationship with the particular Client, and the nature of Personal Information in question. ESAI endeavors to retain Personal Information that it receives from or collects for only as long as is necessary or appropriate to achieve the purposes for which such information was collected, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Automated Decision Making

ESAI does not use automated decision making or profiling in the Processing of Personal Information, and does not make decisions that affect you based on automated decision making or profiling using Personal Information.

Changes to Policy

ESAI reserves the right to change or amend this Policy at any time and for any reason.

Questions or Concerns

For questions or concerns, please contact one of our Privacy OfficerS as follows.

Name: Linda Vojkovsky

Address: 300 Ballardvale Street, Suite 114 Andover MA 01810

Phone number: 978-482-0900

Email address: lvojkovsky@esai.com

Last Updated: 03/16/2026