Virginia Policy

Privacy Policy for Virginia Residents

Last Updated: March, 3rd, 2026

This Privacy Policy (this “Policy”) for Virginia residents supplements the information contained in the Privacy Policy of Calaveras Energy, Inc. (the “Company” or “we”) and applies solely to all visitors, users, and others who reside in the State of Virginia (“consumers” or “you”). The Company has adopted this Policy to comply with the Consumer Data Protection Act (as may be amended from time to time, the “CDPA”) and any terms defined in the CDPA have the same meaning when used in this Policy.

Information We Collect.

Our website (“Website”) collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“Personal Information”). Personal Information does not include:

• Publicly available information from government records;
• Deidentified or aggregated consumer information; or
• Information excluded from the CDPA’s scope, like:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), clinical trial data, or other qualifying research data; or
  
  
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Family Educational Rights and Privacy Act (FERPA), the Farm Credit Act of 1971, the Gramm-Leach-Bliley Act (GLBA), and the Driver’s Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of Personal Information from consumers within the last twelve (12) months:

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice.

We do not sell your Personal Information for monetary consideration.

Our Website obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you, for example, from forms you complete or products and services you purchase;
• Indirectly from you, for example, from observing your actions on our Website; and/or
• Indirectly through social media networks, data analytics companies, and advertising networks.

Use of Personal Information

We use the Personal Information we collect through our Website:

• To fulfill or meet the reason you provided the information, for example, if you share your name and contact information or ask a question about our products or services, we will use that Personal Information to respond to your inquiry; if you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery; we may also save your information to facilitate new product orders or process returns;
• To provide, support, personalize, and develop our Website, products, and services;
• To create, maintain, customize, and secure your account with us;
• To process your requests, purchases, transactions, and payments and prevent transactional fraud;
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law);
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business;
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Information or as otherwise set forth in the CDPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets or equity, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

Your Rights and Choices

The CDPA provides consumers with specific rights regarding their Personal Information. This section describes your rights under the CDPA and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information (the “right to know”). Once we receive your request and confirm your identity (see the “Exercising Your Rights to Know, Correct, or Delete” section below), we will disclose to you:

• The categories of Personal Information we collected about you;

• The categories of sources for the Personal Information we collected about you;

• Our business or commercial purpose for collecting that Personal Information;

• The categories of third parties with whom we share that Personal Information;

• If we disclosed your Personal Information for a business purpose, a list disclosing such disclosures, identifying the Personal Information categories that each category of recipient obtained; and

• The specific pieces of Personal Information we collected about you (also called a data portability request).

You have the right to obtain a copy of your Personal Information that we collect from you up to two (2) times per year.

Right to Correct

You have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes for which we process it.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see “Exercising Your Rights to Know, Correct, or Delete” section below), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• Debug products to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• Comply with a legal obligation; or

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt Out of Certain Processing

You have the right to opt out of the processing of your Personal Information for the purposes of (i) targeted advertising, (ii) the sale of Personal Information, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Exercising Your Rights to Know, Correct or Delete

To exercise your rights to know, delete, or correct described above, please submit a request by either:

• Calling us at +1 (801) 335-9106; or

• Emailing us at support@calaverasenergy.com.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You do not need to create an account with us to submit a request to know or delete (each, a “Verifiable Consumer Request”). However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

Exercising Your Right to Opt Out

To exercise your right to opt out described above, please submit a request by either:

• Emailing us at support@calaverasenergy.com with “Virginia Opt-Out Request” in the subject line and specify whether you are opting out of targeted advertising, sale, and/or profiling.

• Use a recognized Universal Opt-Out Mechanism (UOOM). We honor UOOM signals from Virginia residents. When we receive a valid UOOM signal, we will treat it as a request to opt out of targeted advertising and the sale of Personal Information associated with the browser or device that sends the signal, and, if reasonably linkable, your account.

We will comply with opt-out requests as required by Virginia law and will not use dark patterns or require you to create an account to opt out.

Response Timing and Format; Appeals

We endeavor to substantively respond to a Verifiable Consumer Request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

You have the right to appeal our decision not to act upon your request. We endeavor to substantively respond to a verifiable consumer request for an appeal within sixty (60) days of its receipt. Our written response to your appeal will include an explanation of the reasons for the decision. If you have concerns about the result of the appeal, you have the ability to contact the state attorney general.

We do not charge a fee to process or respond to your Verifiable Consumer Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CDPA. Without limiting the foregoing, unless permitted by the CDPA, we will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services; or

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Sensitive Data

We will not process Sensitive Data about you without first obtaining your consent. Sensitive data includes personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status; the processing of genetic or biometric data for the purpose of uniquely identifying an individual; personal data collected from a known child; and precise geolocation data.

If we know you are under 13 years of age, we will obtain verifiable parental consent before processing your Personal Information and will not process your Personal Information for targeted advertising or sell it.

Changes to Our Privacy Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated Policy on the Website and update this Policy’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Policy, the ways in which the Company collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under Virginia law, please do not hesitate to contact us at:

Phone: +1 (801) 335-9106

Website: www.calaverasenergy.com

Email: support@calaverasenergy.com

Postal Address:

Calaveras Energy, Inc.

212 E Crossroads Blvd

Suite 142

Saratoga Springs, UT 84043