At Fram Energy, Inc., maintaining the trust of our online users is of the utmost importance to us. We have developed this Privacy Policy (the “Policy”) to show our commitment to fair information practices and the protection of our users’ privacy, and to explain how we collect, process, use, and share information about our users. This Policy applies to our company website, framenergy.com, and to all other websites and platforms that are owned or operated by Fram Energy, Inc. or its subsidiaries (referred to collectively herein as “Fram”, “us”, “we” or “our”) and that have this Policy posted (collectively, the “Site” or “Sites”).

Please review this Policy carefully and use the information herein to make informed choices. Feel free to contact us at support@framenergy.com if you have any concerns or questions about our privacy practices. By accessing the Sites or registering for an account, you are agreeing to all of the terms set forth in this Policy.

If you do not agree to this Policy, do not use the Sites or give us any information. Your continued

use of the Sites, or of our services, means that you agree to this Policy.

1. NOTICE CONCERNING CHILDREN

The Sites are not specifically directed at or intended for children under the age of 13, and Fram does not knowingly collect personal information via the Sites from anyone under 13. Any user that believes that Fram has the personal information of a child under the age of 13 in its database should contact us at support@framenergy.com, so that, if necessary, we can remove the applicable information.

2. WHAT PERSONAL INFORMATION WE COLLECT

The types of personal information we obtain about you depends on how you interact with us and our products and services. When we use the term “personal information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

When we collect any information that does not identify you as a specific natural person, such information may not be deemed personal information under applicable law; such information, unless otherwise prohibited by law, may be used and disclosed for any purpose. Similarly, if applicable law requires that we treat non-personal information as personal information, we will use and disclose this information as personal information in accordance with this Policy.

We will collect personal information including, but not limited to, the following:

Basic Identifying Information. This may include your full name, postal and billing address, e-mail

address, and phone number.

Device Information and Network Activity. This may include device identifiers and history and usage information regarding your interactions with our Sites or emails.

Payment Information. This may include bank account information and credit or debit card numbers. Energy Usage Information. This may include information related to your consumption of gas, electricity, and other utilities.

Communications. This may include your communications with us, including emails, reviews, and other content.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collection information about you in a range of ways, including the following:

Directly from You. We collect personal information you provide, such as when you register for an

account, contact us, respond to a survey, or sign up to receive emails or text messages.

Using Online Tracking Technologies. When you visit our website, open or click on emails we send you, or use our platform, we or third parties we work with may automatically collect certain information regarding your usage of the Sites using online tracking technologies such as cookies.

From Social Media Platforms and Networks. If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (such as Instagram, Facebook, Twitter, Google, LinkedIn, YouTube, and Pinterest) in connection with our Sites, we collect information that you disclose to us, or that the social media platforms disclose to us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.

From Other Sources. For example, we may obtain information about you from other sources, such as your landlord, fraud prevention service providers, and vendors that provide services on our behalf (including Stripe).

Do Not Track. Fram understands that some users may have enabled a “do not track” feature or other mechanism intended to provide consumers with a choice regarding the collection of their personally identifiable information; however, consistent with our rights under applicable law, our Sites may not support or respond to do-not-track requests or other signals sent from a web browser.

4. HOW WE USE YOUR PERSONAL INFORMATION

Depending on how you interact with our Site, the personal information we collect and the way in which it is used may vary. We use the information we collect in order to best provide our services. Where you have provided us with your personal information, we may use that information in the following ways:

Providing Services. We use your personal information to provide our services; to process your payments; to provide you receipts and updates; to send notifications to you related to your account; to create, maintain, and otherwise manage your account or profile, including offering functionalities such as saving your transaction history.

Operate and Improve Site and Services. We use your personal information to operate, maintain, and improve our Sites and services, including but not limited to collecting amounts owed to us; identifying and repairing errors or problems; understanding common usage patterns; responding to comments and questions and providing customer service; and sending confirmations, invoices, technical notices, updates, security alerts, support, and other administrative messages.

Promote Security and Prevent Fraud. We use your personal information to detect, investigate, prevent, and respond to possible fraudulent or illegal activity; attempts to manipulate or violate our policies, procedures, and terms and conditions; and security incidents.

Legal Obligations. We use your personal information to comply with our legal and regulatory

obligations, to establish or exercise our rights, and to defend against a legal claim.

5. DISCLOSURE OF PERSONAL INFORMATION

We will not disclose your personal information to third parties except as follows:

• We may share personal information with your consent.

• We may share personal information with third-party service providers that perform services to support our core business functions and internal operations. Their use of your information is not governed by this privacy policy. These third-party services providers include, but are not limited to, Stripe. You can learn more about Stripe and its processing activities in its privacy policy, which can be found at https://stripe.com/privacy.

• We may share personal information for legal, protection, and safety purposes.

• We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

• Personal information is maintained on our servers or those of our service providers, and is

  accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Policy.

• We may share personal information with our affiliates, or when we do a business deal, or

  negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

• We may share personal information with your landlord as needed to provide, monitor, and

  improve the services. For the avoidance of doubt, Fram may share personal information in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable, and anonymous. We may transfer, share, or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. THIRD PARTY LINKS

This Policy applies only to information we collect, process, and use through our Sites. This Policy does not apply to information that we collect through other channels or any third-party websites that you may be able to access from our Sites, which may have data collection and use practices and policies that materially differ from those described in this Policy, or to any services that may be offered by our business partners. We are not responsible for the content or privacy practices of any third-party sites.

7. YOUR LEGAL RIGHTS OVER YOUR PERSONAL INFORMATION

Consistent with applicable law, you may have the right to: (1) access, correct, or delete personal

information or (2) opt out of cookies and other online tracking technologies. Please note that these rights may vary depending on your state of residence. Fram will comply with any rights you may have which apply to Fram. If you want to exercise your rights, please contact us at support@framenergy.com. Please ensure that you include the statement “State Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.

Identity Verification

For us to process some requests, we will need to verify your identity to confirm that the request came from you. We may contact you to verify your request. Depending on your request, we will ask for certain information to help us verify your identity.

Authorized Agent

Depending on applicable law, you may be able to designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

8. CONTACT INFORMATION

We welcome your comments or questions about this Policy. You may contact us at support@framenergy.com.

9. DATA SECURITY

We have implemented commercially reasonable physical, procedural, and technical security measures, designed to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Sites will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. As such, your use of the Sites is at your own risk. When you register an account with us, we encourage you to choose passwords of sufficient length and complexity and not used to access any other site or services, install the latest security updates and anti-virus software on your computer/device to help prevent malware and viruses, not share your password with others, and review your account information periodically.

For your convenience, our Site may include functionality that allows you to remain logged in so that you do not have to re-enter your password each time you want to access your account. If you choose to remain logged in, you should be aware that anyone with access to your device will be able to access and make changes to your account. For that reason, if you choose to remain logged in, we strongly recommend that you take appropriate steps (such as requiring a password when waking your computer from sleep or enabling the “Passcode Lock” security feature on your device) to protect against unauthorized access to, and use, of your account. If there is any unexpected activity or inaccurate information, if you have reason to believe that your information is no longer secure, or if you have any questions about our security,

please contact us using the contact information provided above.

10. CHANGES TO THIS POLICY

We reserve the right to revise this Policy from time to time (for example, to keep up with changes in the law or to reflect changes in how we are doing business). We will post the date it was last updated at the top of this Policy and provide additional notice to you if we make any changes that materially affect your privacy rights.

Last Updated: May 23, 2024