Privacy Policy.

This site is operated by Universal Capital Solutions LLC, doing business as Stratex Oil (“Stratex Oil,” “Stratex,” “we,” “us,” or “our”), a commodity trading and supply company with offices at:

• 2001 L Street N.W., Suite 500, Washington, DC 20036
• 1000 Main Street, Suite 2300, Houston, TX 77002

This Privacy Policy explains how we collect, use, share, and protect personal information in connection with this website (stratexoil.com) and our commercial activities, and describes the rights available to you under applicable law, including the Texas Data Privacy and Security Act (TDPSA), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), other applicable U.S. state privacy laws, and, where applicable, the EU/UK General Data Protection Regulation (GDPR).

Information you provide: name, email address, telephone number, company, job title, and any content you submit through contact forms, counterparty/KYC onboarding, or job applications, including resumes and related materials.

Information collected automatically: IP address, browser type, device information, referring URL, pages visited, and approximate location, collected through cookies, pixels, and analytics tools. See our Cookie Policy for details.

Information from third parties: where applicable, information obtained from counterparty due diligence, sanctions/KYC screening providers, and publicly available sources, as required for regulatory compliance.

Sensitive information in KYC/due diligence: where counterparty or sanctions screening requires government-issued identification numbers (such as passport numbers) or similar identifiers, this information may constitute “sensitive personal information” under the CCPA/CPRA and comparable categories under other state privacy laws.

• To respond to your inquiries and provide the information you request
• To process counterparty onboarding and job applications
• To send market commentary or newsletters where you have subscribed
• To analyze site usage and improve the site’s content and performance
• To comply with legal, regulatory, and contractual obligations, including sanctions and KYC screening

We process personal information on the following legal bases: performance of a contract with you or your organization; our legitimate interests in operating and marketing our business; your consent (which you may withdraw at any time); and compliance with legal obligations, including counterparty and vessel screening required by applicable law.

Where we rely on legitimate interests, those interests include: operating, maintaining, and improving this website and our commercial relationships; marketing our services to prospective counterparties; safeguarding the security and integrity of our network and information systems; and establishing, exercising, or defending legal claims. Where required by applicable law, we balance these interests against your rights and interests before relying on this basis.

We do not sell personal information to third parties for monetary consideration.

Certain analytics tools and embedded third-party content used on this site (including website analytics and the live market-data widget) may involve the transfer of limited automatically-collected information, such as IP address and browsing behavior, to those third parties. Depending on how these tools are configured and the consideration (if any) exchanged with these providers, this activity may constitute a “sale” or “share” of personal information, or “targeted advertising,” under the broad definitions used in the TDPSA and similar state privacy laws, even where no money changes hands.

You have the right to opt out of any sale, sharing, or targeted advertising. To exercise this right, use the “Do Not Sell or Share My Personal Information” link in the website footer, or activate the Global Privacy Control described in Section 11.

Personal information is processed primarily in the United States. Where we transfer personal information originating in the European Economic Area, United Kingdom, or Switzerland to the United States or other countries, we rely on recognized transfer mechanisms, including Standard Contractual Clauses approved by the European Commission and, where applicable, the UK International Data Transfer Addendum, incorporated into our agreements with service providers and counterparties. Additional information about these safeguards is available on request by contacting us using the details in Section 16.

We retain personal information only for as long as necessary for the purposes described in this Policy, taking into account the following retention periods:

We may retain information for longer periods where required by law, regulation, litigation hold, or to resolve disputes.

Subject to applicable law, you may have the right to:

• Access the personal information we hold about you
• Correct inaccurate personal information
• Delete your personal information
• Obtain a copy of your personal information in a portable, readily usable format (data portability)
• Opt out of the sale of personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects
• Withdraw consent, where processing is based on consent
• Appeal a decision we make in response to your request
• Limit the use or disclosure of sensitive personal information, where applicable (California residents)

To exercise these rights, contact us at info@stratexoil.com or at the mailing address in Section 16. We will respond within the time required by applicable law. If we decline to act on your request, you may appeal by replying to our decision with “Appeal” in the subject line; we will respond to appeals within 60 days. If your appeal is denied, Texas residents may submit a complaint to the Texas Attorney General.

We will not discriminate against you for exercising any of these rights.

This website is directed to businesses and professionals and is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors, and we do not knowingly sell or share the personal information of known minors.

See our Cookie Policy for cookie categories, third-party cookies, retention periods, and management options, including how we respond to opt-out preference signals.

Where technically implemented, this website is configured to recognize and honor Universal Opt-Out Mechanisms, including the Global Privacy Control (GPC) signal, as a valid request to opt out of the sale or sharing of personal information and targeted advertising, in accordance with the TDPSA, the CCPA/CPRA, and other applicable U.S. state privacy laws that require recognition of such signals (including Colorado, Connecticut, Delaware, New Jersey, Oregon, and others).

This section applies specifically to California residents and supplements the rest of this Policy. Unlike most other state privacy laws referenced in this Policy, the CCPA/CPRA does not exempt personal information collected in a business-to-business or employment context; the rights below therefore apply to California-based business contacts, counterparties, and job applicants, not only to individual consumers.

In the preceding 12 months, we have collected the categories of personal information described in Section 2 of this Policy, from the sources described in that Section, for the business purposes described in Section 3, and have disclosed such information to the categories of service providers described in Section 14.

In addition to the rights described in Section 8, California residents have the right to:

• Know the specific pieces of personal information we have collected about them
• Limit the use or disclosure of sensitive personal information
• Not be retaliated against for exercising any of these rights (Shine the Light / non-discrimination)

To exercise California-specific rights, or to designate an authorized agent to act on your behalf, contact us using the details in Section 16. We may require you to verify your identity before completing your request.

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet, and no method of electronic storage, is completely secure, and we cannot guarantee absolute security.

In the event of a data breach affecting your personal information, we will notify you and/or the applicable regulators where, and to the extent, required by applicable law.

We engage third-party service providers to help us operate this website and our business. These providers act on our behalf, under contractual confidentiality and data protection obligations, and are authorized to use personal information only as necessary to provide their services to us. Categories of service providers we use include:

• Website hosting and infrastructure providers
• Website analytics providers
• Email and communications providers
• Cloud storage and data management providers
• Sanctions, KYC, and counterparty due-diligence screening providers
• Professional advisers, including lawyers, auditors, and consultants

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, without human involvement.

Universal Capital Solutions LLC, d/b/a Stratex Oil

2001 L Street N.W., Suite 500, Washington, DC 20036

Email: info@stratexoil.com

We may update this Privacy Policy from time to time. The latest version will be posted on this page with the applicable effective date. Material changes will be highlighted where appropriate.