Clarke Energy Fund Management, LLC (“CEFM,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you provide to us.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit cefmoilandgasinvestments.com and any related webpages, forms, services, or communications that link to this Privacy Policy (collectively, the “Website”).

By using the Website or submitting information to us, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

We may collect personal information directly from you, automatically through your use of the Website, and from third-party sources.

Information You Provide to Us

When you complete a form, request information, request a callback, communicate with us, or inquire about an investment opportunity, we may collect information such as:

• Your first and last name
• Email address
• Telephone number
• Mailing address
• Company name, occupation, or professional information
• Preferred contact method
• Information concerning your investment interests
• Information concerning your accredited-investor status
• Estimated income, net worth, investment experience, or investment eligibility
• The amount or range you may be interested in investing
• Information included in messages or questions you submit
• Records of your communications with us
• Any other information you voluntarily provide

Please do not submit Social Security numbers, banking information, account passwords, or other highly sensitive information through a general website contact form unless we specifically request it through an appropriate secure process.

Information Collected Automatically

When you visit the Website, we and our service providers may automatically collect information such as:

• Internet Protocol address
• Browser type and version
• Device type and operating system
• Referring website or advertisement
• Pages viewed
• Links clicked
• Date and time of your visit
• Approximate geographic location
• Website interactions and form activity
• Cookie identifiers and similar device identifiers

We may collect this information through cookies, pixels, analytics tools, server logs, and similar technologies.

Information From Other Sources

We may receive information from advertising platforms, analytics providers, referral partners, event organizers, publicly available sources, professional databases, or other persons who refer potential investors to us.

We may combine information obtained from these sources with information you provide directly.

2. How We Use Personal Information

We may use personal information to:

• Respond to questions, inquiries, and requests for information
• Contact you regarding current or future oil and gas investment opportunities
• Determine whether an opportunity may be appropriate for your stated interests
• Evaluate or verify whether you qualify as an accredited investor
• Provide information concerning private-placement offerings
• Schedule calls, meetings, presentations, or follow-up communications
• Send newsletters, market updates, educational materials, company updates, and promotional communications
• Conduct ongoing email, telephone, direct-mail, or digital marketing
• Maintain and manage prospective-investor and investor relationships
• Record your communication and marketing preferences
• Operate, maintain, secure, and improve the Website
• Measure Website traffic, advertising performance, and marketing effectiveness
• Detect fraud, misuse, security incidents, or unlawful activity
• Comply with securities laws, recordkeeping requirements, legal obligations, court orders, or regulatory requests
• Establish, exercise, or defend legal claims
• Complete a merger, financing, acquisition, restructuring, sale, or transfer of all or part of our business
• Carry out other purposes disclosed to you when information is collected

Submitting information through the Website does not create an advisory, brokerage, fiduciary, partnership, or investor relationship.

3. Marketing Communications

When you provide your contact information, we may use it to communicate with you about CEFM, oil and gas investments, private-placement opportunities, educational information, company developments, and related products or services.

Email Marketing

You may unsubscribe from promotional emails by clicking the unsubscribe link contained in an email or by contacting us using the information below.

Even after you unsubscribe from marketing communications, we may continue to send non-promotional communications relating to an existing relationship, a pending transaction, legal notices, security matters, or other administrative purposes.

Telephone Calls and Text Messages

When you provide a telephone number, you authorize us to contact you at that number in response to your request and for other purposes permitted by applicable law.

We will not use automated technology to send marketing text messages or place marketing calls when prior express written consent is legally required unless the appropriate consent has been obtained.

Consent to receive marketing calls or text messages is not a condition of purchasing or investing. Message and data rates may apply. Message frequency may vary. You may revoke consent to marketing text messages by replying STOP or by contacting us.

4. Cookies and Similar Technologies

We may use cookies, pixels, tags, analytics technologies, and other tracking tools to:

• Keep the Website functioning
• Remember user preferences
• Understand how visitors use the Website
• Identify technical problems
• Measure advertising campaigns
• Determine which advertisements or referrals resulted in Website visits or inquiries
• Deliver or improve advertising on other websites and platforms

Third-party services, including analytics providers, social-media platforms, and advertising networks, may place or access cookies or similar technologies through the Website.

You may be able to control cookies through your browser settings or through a cookie-preference tool provided on the Website. Blocking certain cookies may affect Website functionality.

5. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

Service Providers

We may provide information to companies that perform services on our behalf, including:

• Website hosting and maintenance providers
• Customer relationship management platforms
• Email and marketing providers
• Telephone and communications providers
• Analytics providers
• Advertising and social-media platforms
• Cybersecurity and information-technology providers
• Data storage and document-management providers
• Accountants, attorneys, consultants, and other professional advisers

These parties may use personal information to perform services for us, subject to applicable contractual and legal restrictions.

Offering and Business Participants

When appropriate in connection with a prospective or actual investment, we may disclose information to:

• Project sponsors
• Issuers
• Operators
• Affiliates
• Managing members
• Fund administrators
• Subscription-document providers
• Verification providers
• Banks or payment processors
• Broker-dealers, placement agents, or other regulated financial professionals
• Attorneys, accountants, tax professionals, and compliance providers

Any investment opportunity will be governed by its applicable offering documents, subscription agreements, investor questionnaires, and related disclosures.

Advertising and Analytics Providers

We may disclose online identifiers, Website activity, device information, and related information to analytics providers and advertising platforms to measure campaigns, understand Website usage, and provide relevant advertising.

Depending on applicable state law, some advertising activities may be considered “sharing,” “targeted advertising,” or a “sale” of personal information, even when no money is exchanged.

Legal and Regulatory Disclosures

We may disclose information when we believe disclosure is necessary to:

• Comply with applicable law or legal process
• Respond to a subpoena, court order, government inquiry, or regulatory request
• Cooperate with securities regulators or law-enforcement agencies
• Protect our rights, property, business, investors, users, or others
• Investigate suspected fraud, security incidents, or unlawful conduct
• Enforce our agreements or policies

Business Transactions

Information may be disclosed or transferred as part of a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar business transaction.

6. Sale and Sharing of Personal Information

CEFM does not sell personal information for money in the traditional sense.

However, certain uses of analytics cookies, advertising pixels, and digital advertising services may be treated as a “sale,” “sharing,” or use for targeted advertising under some state privacy laws.

Where required, eligible individuals may request to opt out of these activities by using the Website’s cookie-preference tool or by contacting us as described below.

We do not knowingly sell or share the personal information of individuals under 16 years of age.

7. Accredited-Investor Information

Some investment opportunities discussed through the Website may be limited to accredited investors.

We may ask you to provide information concerning your income, net worth, business position, professional credentials, investment experience, entity status, or other qualifications. We may also ask you to provide documentation or obtain verification from an attorney, certified public accountant, registered broker-dealer, investment adviser, or another qualified third party.

Providing preliminary information through the Website does not establish that you are an accredited investor and does not guarantee that you will be eligible to participate in any offering.

Additional privacy notices or disclosures may apply during the accreditation, subscription, due-diligence, or investment process.

8. Data Retention

We retain personal information for as long as reasonably necessary to:

• Respond to inquiries
• Maintain prospective-investor and investor relationships
• Conduct permitted marketing
• Administer investment-related activities
• Maintain business and communication records
• Comply with legal, tax, securities, regulatory, and recordkeeping obligations
• Resolve disputes
• Enforce agreements
• Protect against fraud or security risks

Retention periods may vary depending on the nature of the information and our legal obligations.

When information is no longer reasonably required, we may delete, anonymize, aggregate, or securely dispose of it.

9. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no website, electronic transmission, storage system, or security measure is completely secure. We cannot guarantee the absolute security of information transmitted to or maintained by us.

You should use caution when submitting information online and should not transmit highly sensitive information through unsecured email or general contact forms.

10. Your Privacy Rights

Depending on where you reside and subject to applicable law, you may have the right to:

• Request confirmation that we process your personal information
• Request access to personal information we maintain about you
• Request correction of inaccurate personal information
• Request deletion of personal information
• Request a portable copy of certain personal information
• Opt out of the sale or sharing of personal information
• Opt out of targeted advertising
• Restrict or limit certain uses of sensitive personal information
• Withdraw consent when processing is based on consent
• Appeal a decision concerning a privacy request
• Receive equal service and not be unlawfully discriminated against for exercising a privacy right

These rights are not absolute. We may deny or limit a request when permitted by law, including when information must be retained for legal, regulatory, security, recordkeeping, contractual, or fraud-prevention purposes.

Submitting a Request

To submit a privacy request, contact us using the information in the “Contact Us” section below.

Please include:

• Your name
• The email address or telephone number associated with your request
• Your state of residence
• The privacy right you wish to exercise
• Sufficient information for us to locate your records

We may need to verify your identity before completing a request. Authorized agents may submit requests when permitted by applicable law, but we may require evidence of the agent’s authority and verification of the consumer’s identity.

11. California Privacy Notice

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to CEFM.

During the preceding 12 months, we may have collected the following categories of personal information:

• Identifiers, including names, addresses, email addresses, telephone numbers, IP addresses, and online identifiers
• Customer-record information, including contact and financial-qualification information
• Commercial information, including investment interests and interaction history
• Internet or electronic-network activity
• Approximate geolocation information
• Professional or employment-related information
• Inferences concerning investment interests or preferences
• Sensitive personal information, when voluntarily provided or necessary to evaluate financial qualifications

We may collect these categories directly from consumers, automatically through the Website, from service providers, from advertising or referral sources, and from publicly available sources.

We use and disclose these categories for the business and commercial purposes described in this Privacy Policy.

We do not use sensitive personal information to infer characteristics about individuals beyond purposes reasonably necessary to provide requested services, evaluate qualifications, comply with law, prevent fraud, or administer investment-related activities.

California residents may request access, correction, or deletion and may request to opt out of activities legally considered a sale or sharing of personal information. We will not unlawfully discriminate against a California resident for exercising a privacy right.

12. Do Not Track and Preference Signals

Some browsers offer a “Do Not Track” setting. Because there is not a universally accepted standard for responding to Do Not Track signals, the Website may not respond to every such signal.

Where required by applicable law and supported by our systems, we will process recognized universal opt-out preference signals, such as Global Privacy Control, as a request to opt out of the sale or sharing of personal information for the applicable browser or device.

13. Third-Party Websites

The Website may contain links to third-party websites, platforms, documents, or services.

We do not control and are not responsible for the privacy, security, content, or practices of third parties. This Privacy Policy does not apply to information collected independently by third parties. You should review their privacy policies before providing information.

14. Children’s Privacy

The Website and the investment opportunities described through it are intended for adults and are not directed to children under 18 years of age.

We do not knowingly collect personal information from children under 13. If we discover that we have collected personal information from a child under 13 without legally valid authorization, we will take reasonable steps to delete it.

15. International Visitors

The Website is operated from the United States. If you access it from another country, your information may be transferred to, stored in, and processed in the United States, where privacy laws may differ from those in your jurisdiction.

16. Investment and Securities Disclaimer

The Website is provided for general informational purposes.

Nothing in this Privacy Policy or on the Website constitutes personalized investment, legal, accounting, or tax advice. Investing in oil and gas ventures involves substantial risk, including the possible loss of an investor’s entire investment.

Nothing on the Website constitutes an offer to sell or a solicitation of an offer to purchase securities. Any offering will be made only through applicable offering documents, including a Private Placement Memorandum, subscription documents, and related disclosures, and only to persons who satisfy the applicable eligibility requirements.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our information practices, Website functionality, services, or legal requirements.

The revised policy will be posted on the Website with an updated “Last Updated” date. Material changes may also be communicated through other reasonable means when required by law.

Your continued use of the Website after an updated Privacy Policy becomes effective constitutes acknowledgment of the revised policy.