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OPIS PRIVACY POLICY

Privacy Policy

Effective Date: February 28, 2022

Oil Price Information Services LLC and Dow Jones Energy Limited (collectively,
“OPIS,” “us,” “we,” or “our”) are committed to protecting your privacy and
providing you with a positive experience while using our websites, products, or
services (“Platforms”). OPIS wants you to be familiar with how we collect, use,
and disclose information from and about you because we respect your concerns
about privacy, and we want to maintain your trust.

OPIS reserves the right, at any time, to modify this Privacy Policy. OPIS may
periodically update this Privacy Policy without prior notice to reflect changes
in our practices. Please look at the Effective Date at the top of this Privacy
Policy to see when this Privacy Policy was last revised and note that any
changes to this Privacy Policy will become effective when we post the revised
Privacy Policy on the OPIS websites. We will notify you by posting a prominent
notice on the OPIS websites indicating we have updated this Privacy Policy. Your
use of the Platforms or your provision of Personal Data to us following these
changes means you acknowledge you have read and accept the revised Privacy
Policy. You should review this Privacy Policy periodically so that you keep up
to date on our most current policies and practices.

1. Scope

This Privacy Policy applies to information we collect across our Platforms that
link to this Privacy Policy. This Privacy Policy also describes generally OPIS’
practices for handling Personal Data collected through the Platforms or from a
third party and provides you with guidance on your rights and obligations in
relation to your Personal Data.

Please note that some privacy rights and obligations may differ in certain
locations based on local law, in which case OPIS will comply with the local
legal requirements. To the extent a notice provided at the time of collection
from a website or specific product conflicts with this Privacy Policy, such
specific notice will control.

Your decision to use the Platforms and provide your Personal Data is voluntary.
We indicate on our online, mobile, and other registration forms what types of
Personal Data are requested. You may choose not to submit requested information
online, or may choose to restrict the use of cookies (see our Cookie Policy, for
more information), but that may limit the services that OPIS is able to provide
to you.

The OPIS Platforms are a network of general audience sites, and are not targeted
to, and do not knowingly collect Personal Data from, minors under 16 years of
age. We request that these individuals do not provide Personal Data through the
OPIS Platforms.

2. Collection of Personal Data

OPIS and our service providers collect Personal Data to offer services you have
requested or that we have a legitimate interest to believe are of interest to
our customers, to manage the relationships we have with our customers and
partners, and to perform activities based on your consent. OPIS and our service
providers may collect the following information from and about you:

2.1 Personal Data
For purposes of this Privacy Policy, “Personal Data” is the information that
identifies you as an individual or relates to an identifiable person. This may
include identifiers such as your name, physical address, email address, phone
number, login information, marketing preferences, company affiliation, payment
information, or geographic location

2.1.1 Personal Data You Submit
We collect Personal Data when you submit it to us, such as when you register for
or subscribe to certain products or services; create a profile; visit our
Platforms; use an interactive feature (such as chat, chat bot, or article
sharing options); register for an event or conference; or contact customer
service.

2.1.2 Personal Data We Receive From Third Parties
To the extent permitted by applicable law, OPIS may also collect Personal Data
from trusted third-party sources such as social media services or commercially
available sources and engage third parties to collect Personal Data to assist us
with providing our services to you. One of the most common methods of collecting
Personal Data is during the online form submission or registration process,
including where a website user is requesting a free trial or a courtesy
newsletter, registering for an event, or responding to similar offers such as
sample reports, white papers, or further product information.

2.2 Other Information
In some instances, OPIS and the third parties we engage may automatically
collect and aggregate data using cookies, weblogs, web beacons, and other
similar applications. This information is used to better understand and improve
the usability, performance, and effectiveness of our Platform and to help us
tailor content or offers for you. Please see our Cookie Policy for more
information.

The OPIS Platforms may also be linked to sites or apps operated by third
parties, and may carry advertisements or offer content, special offers,
functionality, games, or applications developed and maintained by third parties,
using iframes, tools, or plug-ins (“Linked Services”). These third party Linked
Services may use automated means to collect information about you and your use
of these features. OPIS is not responsible for the privacy practices of such
third parties, and once you leave the OPIS Platforms or click an advertisement,
or sign up for a special offer, you should check the applicable third-party
privacy notice.

3. Purpose and Use of Personal Data

OPIS may use your Personal Data for operational, legal, administrative, and
other legitimate purposes permitted by applicable law. Some of the ways we may
use Personal Data include:

 * Providing you with requested products or services.
 * Providing you with information regarding similar products or events.
 * Analyzing and monitoring extent of use.
 * Providing customized product and service information.
 * Allowing users to participate voluntarily in mailings or other events.
 * Providing product service updates, information, and alerts.
 * Sending communications, including for marketing or other customer
   satisfaction purposes.
 * Order processing and to provide transaction documents.
 * To contact users for information verification purposes.
 * Analyzing and monitoring extent of use and enhancing OPIS’ Platforms.
 * Conducting due diligence activities for financial institutions and other
   regulated companies.

4. Sharing Personal Data

To support the purposes listed in Section 3 above, OPIS may share or disclose
Personal Data to:

 * OPIS’s parent, affiliates and other related companies.
 * The organization that arranges your access to our products or services (if
   that is not you) to fulfill its contractual obligations and to provide our
   products and services.
 * Service providers and business partners for the purposes of operating our
   business, delivering, improving, and customizing our products or services,
   sending marketing and communications related to our business, payment
   processing, and for other legitimate purposes permitted by applicable law or
   otherwise with your consent.

In addition, we may share your Personal Data with non-affiliated third parties
when sharing is permitted by you or authorized by this Privacy Policy in order
to:

 * Allow third party service providers, such as contractors, agents, or sponsors
   who help us manage or provide our products and services. These third-party
   service providers are required to protect Personal Data entrusted to them and
   not use it for any other purpose than the specific service they are providing
   on our behalf.
 * Honor a request that you have made through the products or services.
 * Comply with the law or in response to a court order, government request, or
   other legal process.
 * Protect the interests, rights, safety, or property of OPIS or others.
 * Protect against fraud or for risk management purposes.
 * Respond to adverse third parties (i.e., adverse parties and their counsel and
   other agents) in the context of litigation.

In addition, if OPIS sells all or part of its business or makes a sale or
transfer of assets, or is otherwise involved in a merger, reorganization,
dissolution, liquidation, or transfer of all or part of its business, OPIS may
transfer your Personal Data to a third party as part of that transaction. You
may be informed of the identity and contact details of the third party where
required by applicable law. In all cases OPIS requires all unaffiliated third
parties to treat Personal Data as confidential.

If you participate in a discussion forum, chat room, or provide comments related
to OPIS on a social media or other public platform, you should be aware that the
information you provide there (i.e., your public profile) will be made broadly
available to others, and could be used to contact you, send you unsolicited
messages, or for purposes neither OPIS nor you have control over. Also, please
recognize that social media forums and chat rooms not controlled by OPIS may
have additional rules and conditions. OPIS is not responsible for the Personal
Data or any other information you choose to submit on these forums that are not
OPIS controlled.

The Platforms may offer you the ability to share Personal Data through a social
networking site (e.g., Facebook, Twitter), using integrated tools (e.g.,
Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated
tools enables you to share Personal Data about yourself with other individuals
or the public, depending on the settings that you have established with such
social networking site. For more information about the purpose and scope of data
collection and use in connection with such social networking site or a site’s
integrated tools, please visit the privacy policies of the entities that provide
these social networking sites.

5. Security of Personal Data

OPIS has physical, administrative, and technical safeguards in place to help
protect the Personal Data OPIS collects. While there is no such thing as perfect
security on the Internet, we will take reasonable and appropriate steps to
ensure the safety of your Personal Data.

6. Retention of Personal Data

We will retain your Personal Data for the period necessary to fulfill the
purposes outlined in this Privacy Policy unless a longer retention period is
required or allowed by law.

7. Cookies we use and their purpose

Our Platforms use cookies and other tracking technologies to function
effectively and deliver certain features. For more information about how we use
cookies and tracking technologies, please refer to our Cookie Policy.

8. Other Contractual Relationships

If you enter into a separate contractual relationship with OPIS which requires,
or contemplates, collecting, using, or sharing information about you in a manner
that is different than that which is described in this Privacy Policy, the terms
of that agreement will apply.

9. Other Websites

This Privacy Policy does not apply to sites or applications offered by other
companies or individuals, including third party products and services, that may
be displayed as content in a search on our website. OPIS encourages you to read
the privacy policy of any third-party site or applications before transmitting
Personal Data.

10. Region-Specific Privacy Notices

California Privacy Rights

10.1 Residents of California

The California Consumer Privacy Act of 2018 (“CCPA”) provides specific rights to
California residents, which are detailed below. Where indicated, certain terms
in this section have the meaning given to them in the CCPA.

10.1.2 California Notice of Collection

The following chart lists the categories of Personal Information (as defined in
the CCPA) we, in the past 12 months, may have collected from and about
individuals who use our Platforms.

CategoryCategory Description

Collected

IdentifiersA real name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address, account name,
national identification number (including SSN), driver’s license number,
passport number, or other similar identifiers.Protected classification
characteristics.Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition, physical or
mental disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including familial genetic
information).Commercial information.Records of personal property, products or
services purchased, obtained, or considered, or other purchasing or consuming
histories, or tendencies.Biometric information.Genetic, physiological,
behavioral, and biological characteristics, or activity patterns used to extract
a template or other identifier or identifying information, such as,
fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,
gait, or other physical patterns, and sleep, health, or exercise data.

X

Internet or similar network activity.Browsing history, search history,
information on a consumer’s interaction with a website, application, or
advertisement.Geolocation data.Specific physical location or movements.

X

Sensory data.Audio, electronic, visual, thermal, olfactory, or similar
information.

X

Professional or employment-related information.Current or past job history or
performance evaluations.Non-public education information.Education records
directly related to a student maintained by an educational institution or party
acting on its behalf, such as grades, transcripts, class lists, student
schedules, student identification codes, student financial information, or
student disciplinary records.

X

Inferences drawn from other personal information.Profile reflecting a person’s
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.OtherPersonal information
categories listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e), such as name, signature, Social Security Number, physical
characteristics or description, address, telephone number, passport Number,
driver’s license or state identification card number, insurance policy number,
education, employment, employment history, bank account number, credit card
number, debit card number, or any other financial information, medical
information, or health insurance information. Some personal information included
in this category may overlap with other categories.

As set forth in greater detail in this Privacy Policy, the sources of personal
information we process are you, third parties, and automatic collection of
information through our Platforms. Our purposes in processing personal
information are to provide, measure, and improve our products and services; to
market and advertise to you; and to protect the rights of OPIS and others. Third
parties with whom information may have been shared are our affiliates, service
providers, third parties engaged in marketing and advertising activities,
government authorities or parties to a merger or acquisition agreement. Personal
data may also be disclosed or made available to third parties engaged in
interest-based advertising for their direct marketing purposes.

10.1.2 California Data Subject Rights

Right to Know
You may have the right to request the following information about the Personal
Data we may have collected about you during the past 12 months:

 * the categories and specific pieces of Personal Data we may have collected
   about you;
 * the categories of sources from which we collected the Personal Data;
 * the business or commercial purpose for which we collected or shared the
   Personal Data;
 * the categories of third parties with whom we shared the Personal Data;
 * the categories of Personal Data we sold (per CCPA), or disclosed for a CCPA
   business or commercial purpose, and
 * the categories of third parties to whom we sold (per CCPA), or disclosed for
   a CCPA business or commercial purpose, that information.

Right to Delete
You may have the right to request that we delete the Personal Data we have
collected from you.
Certain information may be exempt from such requests under applicable law. In
addition, we may need to retain certain information for recordkeeping purposes
and/or to provide our services to you. If you submit a request to delete, you
may no longer be able to access or use our services.

Right to Nondiscrimination
We will not deny, charge different prices for, or provide a different level of
quality of goods or services if you choose to exercise CCPA Privacy Rights.

Do Not Sell/Right to Opt Out of Sale of Personal Data
You have the right to opt out of the sale of your Personal Data. Sale under
California law may include sharing of Personal Data and other information with a
third party for monetary or other consideration, such as allowing third parties
to receive certain information including IP address and/or browsing behavior to
deliver interest-based (also called targeted) advertising, or the sharing of a
print mailing address with unaffiliated third-party companies whose products and
services may be of interest to you. You may exercise your Do Not sell Right
here.

California Shine the Light Law
The California Shine the Light Law also permits California residents to request
certain information regarding our disclosure of Personal Data during the past 12
months to third parties for their own direct marketing purposes. To make such a
request, California residents can write to us at energycs@opisnet.com, Attn:
Compliance Officer, Re: CA Shine the Light, and include your name and the
address to which you would like us to respond.

European Economic Area

10.2 Residents of the European Economic Area, United Kingdom and Switzerland

If you are a resident of the European Economic Area (EEA), United Kingdom (UK)
and Switzerland, OPIS may process your information where it has a legal basis
for doing so, such as the following:

 * We may process your personal information to perform a contract, such as
   providing a product or service that you have requested.
 * We may process your personal information so that we can comply with a legal
   requirement that is applicable to us.
 * We may process your information where you have consented to a processing
   activity, such as agreeing that we may share certain of your information with
   third parties.
 * We may process your information where necessary to further our legitimate
   interests, such as fraud prevention and marketing, where such processing will
   not unduly harm your rights and interests.

Residents of the EEA, UK, and Switzerland have the following rights with respect
to the processing of their data.

Right of access
You may have the right to access your personal information to review, update,
and correct inaccuracies. There are some exemptions, which means you may not
always receive all the information we process. Additionally, there may be limits
to the amount of information we will provide access to. For example, in some
cases, we may limit access to personal information where the request is
manifestly unfounded or excessive, in particular because of the requests have
been repetitive in character, or where doing so would violate the rights of
others.

Right to rectification
You may have the right to ask us to rectify personal information you think is
inaccurate. This could also include the right to ask us to complete information
you think is incomplete.

Right to erasure
In some circumstances and subject to certain exceptions, you may have the right
to ask us to erase your personal information.

Right to restrict processing
In certain circumstances, you may have the right to ask us to restrict the
processing of your information.

Right to object to the processing of your personal information
You may have the right to object to the processing of your information. The
right to object to the processing of personal information is most commonly used
by individuals when asking a business to cease direct marketing.

Right to data portability
In some circumstances, you may request copies of your information in a portable
and, to the extent technically feasible, readily usable format that allows you
to transmit this information to another entity without hindrance.

11. How to Exercise Your Privacy Rights

If you would like to exercise any privacy rights available to you can send a
Privacy Request using any of the methods detailed below in the Contact Us
section. California residents may also use the Do Not Sell My Personal
Information link.

Upon receipt of a valid request, we will take the necessary steps to assess and
respond. For your protection, we may only implement requests with respect to the
Personal Data associated with the particular email(s) you provide in your
privacy request, and we will take steps to verify your identity before granting
access to your Personal Data or complying with your privacy request. For
example, we may verify your privacy request by matching information you provide
with our records, or you may be asked to log in to your online account (if
applicable).

You can use an authorized agent to submit your privacy request. If you use an
authorized agent, in addition to verifying the privacy request itself, we will
also verify the authorized agent’s ability to act on your behalf (they should
submit written permission to act on your behalf or a power of attorney).

Once we have verified your identity (and your authorized agent, as applicable),
we will respond to your privacy request as appropriate. If we are unable to
complete your privacy request in whole or in part, we will let you know why.

Because your Personal Data—for example, your email address—is often required to
access or use OPIS Platforms and technologies, we retain Personal Data as long
as your account is active. You may have the opportunity to correct, update, or
modify this information by logging into your account and updating your
information online. Please note that some information may be retained in our
systems, where permitted by law, even after you request deletion.

12. Cross Border Transfer of Personal Data

As a global organization, we may store, transfer, or process your Personal Data
in any country where we have facilities or in which we engage agents,
contractors, service providers, and other third parties. These countries may be
outside your country of residence, including the United States, and may have
different data protection laws than in your country.

If you are located in the EEA, UK, or Switzerland, we will implement appropriate
safeguards to protect your Personal Data as required if we transfer it outside
of the jurisdiction in which you reside. By providing your Personal Data to OPIS
you consent to OPIS’ storage, transmission to, and processing of, your Personal
Data in any jurisdiction.

13. Contact Information

If you have any questions or concerns related to this Privacy Policy, please
contact us at energycs@opisnet.com.

Or you may write to:
OPIS
2099 Gaither Road
5th Floor
Rockville, MD 20850
Attn: OPIS Compliance Director

If OPIS needs, or is required, to contact you concerning any event that involves
information about you, we may do so by email, telephone, or mail.

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