Legal

Privacy policy

What we collect, why, who we share it with, and your rights.

1. Scope

This policy describes how Fifth Meridian Energy, Inc. collects, uses and shares personal information through the website and investor portal. It applies to visitors, prospective investors and shareholders, including shareholders claiming pre-conversion shares.

2. What we collect

Identity and contact data — name, address, date of birth, nationality, government identification documents, tax identification numbers and selfie/liveness data collected during onboarding. Financial and eligibility data — income, net worth and accreditation evidence, source-of-funds information, bank details and wallet addresses. Transaction data — subscriptions, conversions, distributions, repurchases and on-chain activity associated with a wallet you designate. Technical data — IP address, device and browser information, and usage logs. Communications — messages you send us, including through the contact form.

3. Why we use it

To verify your identity and eligibility as required by anti-money-laundering, sanctions and securities laws; to administer your shares, pay distributions and maintain the shareholder register; to comply with tax reporting (Forms 1099-DIV, 1042-S and related filings); to enforce Regulation A investment limits; to secure the Platform and detect fraud; to respond to your inquiries; and, with your consent where required, to send you company updates. Our legal bases include performance of a contract, compliance with legal obligations, and our legitimate interests in operating a secure and compliant platform.

4. Who we share it with

Service providers acting on our behalf, including identity verification, accreditation verification, sanctions and blockchain-analytics screening, payment and custody providers (Coinbase), banks, the registered transfer agent, auditors, reserve engineers and cloud hosting. Regulators, tax authorities, courts and law enforcement where required. Professional advisers under confidentiality. A successor in the event of a reorganisation or sale. We do not sell personal information.

5. Blockchain data

Wallet addresses you designate for payouts, and the transactions to them, are recorded on public blockchains and cannot be deleted. We do not publish your identity on-chain; the share ledger maps addresses to verified status, not to names. Anyone who knows your address can see its balance and transactions.

6. International transfers

We operate in the United States and use providers in other countries. Where we transfer personal data from the EEA, UK or other jurisdictions with transfer restrictions, we rely on standard contractual clauses or other approved mechanisms.

7. Retention

We keep onboarding, register and transaction records for at least five years after the end of your relationship with us, or longer where required by anti-money-laundering, securities, corporate or tax law. Technical logs are retained for a shorter period consistent with security needs.

8. Security

We use encryption in transit and at rest, access controls, multi-party approval for treasury movements, and independent security testing. No system is perfectly secure; please protect your credentials and wallet keys.

9. Your rights

Depending on where you live, you may have the right to access, correct, delete or port your personal data, to object to or restrict certain processing, to withdraw consent, and to complain to a supervisory authority. Some rights are limited where we must retain data by law. To exercise a right, contact investors@fifthmeridian.ai.

10. Cookies

We use strictly necessary cookies for sessions, security (CSRF) and short-lived status messages. We do not use advertising cookies or third-party trackers on this site.

11. Children

The Platform is not directed at anyone under 18 and we do not knowingly collect their data.

12. Changes

We may update this policy and will post the revised version with a new effective date. Material changes will be notified to shareholders by email.

Last updated Sep 1, 2026. Questions: investors@fifthmeridian.ai.