PRIVACY POLICY

PRIVACY POLICY

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Corey G.

Spring Creek, WY

Merit Energy Company Privacy Notice

Last Updated: October 2025

Merit Energy Company and its affiliates (collectively, “Merit”) respect your right to privacy and know you care about how we use and share your information. This Privacy Notice (this “Notice”) describes how Merit collects, shares, uses and protects Personal Information (defined below) in accordance with the requirements of privacy laws in the jurisdictions in which Merit operates.

By using Merit’s website and other websites that we operate (“Our Site(s)”) including those where we post a direct link or otherwise reference this Privacy Notice (this “Notice”), you are accepting and consenting to the practices described in this Notice.

This Notice explains:

  • Defining Personal Information
  • Why we collect Personal Information;
  • Sources of Personal Information;
  • What Personal Information we collect;
  • How we collect Personal Information;
  • Consent to collection;
  • How we use Personal Information;
  • Lawful basis for processing Personal Information
  • Sharing Personal Information;
  • Security measures
  • Retention of Personal Information;
  • Managing your Personal Information
  • Personal Information transferred from the United Kingdom, the European Union or European Economic Area;
  • Rights of Persons Domiciled in UK, EU and EEA;
  • Rights of Persons Domiciled in California;
  • Where this Notice can be accessed;
  • Use of Cookies on Merit’s website, owner portal, investor portal, and other Sites;
  • How to Contact us; and
  • Changes to this Notice.

DEFINING PERSONAL INFORMATION

Various laws and regulations use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories. At Merit, we have chosen to adopt the broader approach to what information must be protected and kept private. For the purpose of this Notice, “Personal Information” means any information that (i) directly and clearly identifies an individual, or (ii) can be used in combination with other information to identify an individual. It can include name, physical address, email address, phone number, IP address, date of birth, social security number, passwords, credit card or other financial or payment information, and more. Personal Information does not include such information if it is anonymous or if it has been rendered de-identified by removing personal identifiers.

WHY WE COLLECT PERSONAL INFORMATION

Various information may be gathered about you and your accounts so that we can (i) provide the services we offer, (ii) know who you are in order to prevent unauthorized access to your information, and (iii) comply with the laws and regulations that govern Merit. This may be information about you that you provide to us by filling in forms on our Site(s), corresponding with us by phone, electronic mail or otherwise, or through in-person visits. It includes information that you provide when you register to use our Site(s) or otherwise engage with the Site(s).

SOURCES OF PERSONAL INFORMATION

Generally speaking, Merit may collect Personal Information from the following sources:

  • Information we receive about you on applications or other forms;
  • Information you provide to us orally;
  • Information we receive from a consumer reporting agency; and
  • Information we receive in connection with your transactions with us, our affiliates or others.

Merit may choose to combine the Personal Information with information Merit obtains from its business partners or other affiliated companies in furtherance of Merit’s business purposes.

This Notice applies to users of Merit’s website (www.meritenergy.com), investors and potential investors in Merit’s investment funds, royalty owners and other owners of oil and gas interests owned and/or operated by Merit, Merit’s vendors, Merit’s employees, persons who communicate with Merit, including emails and telephone calls received by Merit’s Land, Accounting, Investor Relations and other departments, and other stakeholders of Merit. When you use our services, you acknowledge that you have read and understand the contents of this Notice.

WHAT PERSONAL INFORMATION WE COLLECT

Merit does not collect more information than is needed to conduct its business and satisfy any associated regulatory requirements. The following are examples of the types of Personal Information that we may collect:

  • Name, address, phone number and email address;
  • Age, date of birth, occupation and marital status;
  • Photo identification including driver’s license or ID card and passport numbers;
  • Personal identifier, depending on your country of residence, such as your Social Security Number; and
  • Financial information, account balances and assets, and representations required under applicable law or regulation concerning your financial resources.

HOW WE COLLECT PERSONAL INFORMATION

Merit may collect information from you during an onboarding process or in connection with an acquisition of oil and gas assets. When Merit collects data from you directly, we will provide Merit’s contact information and Merit’s purpose for collecting and processing the data. Merit may also obtain information about you from other sources (e.g. consultants, financial advisory firms, or public registers for background searches, address verifications, etc.).

CONSENT TO COLLECTION

By providing your data, you consent to its collection, processing, use, transfer and storage. It is in your sole discretion to provide Personal Information to us, and your consent can be withdrawn at any time by providing adequate notice (see below) to Merit. However, if you do not provide us with all or some of the Personal Information we request, or withdraw your consent, we may not be able to (i) accept an engagement from you, (ii) provide all or some of our services, (iii) enter into a contract with you, or (iv) send you information about us (e.g. marketing materials).

HOW WE USE PERSONAL INFORMATION

We use Personal Information for a variety of business purposes, including but not limited to, the following:

  • To administer, facilitate and manage your relationship and/or account(s) with Merit;
  • To contact you or your designated representative(s) in connection with your relationship and/or account;
  • To monitor and audit compliance with our internal policies and procedures; and
  • To comply with and enforce applicable legal and regulatory requirements.

If your relationship with Merit ends, we will continue to treat your personal information, to the extent we retain it, as described in this Notice.

LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION

There may be a need to process Personal Information for the purposes set out in this Notice as a matter of contractual necessity under, or in connection with, an applicable agreement, and in the legitimate interests of Merit to operate its business. From time to time, Merit may need to process the Personal Information on other legal bases, including compliance with a legal obligation, or if it is necessary to protect the interests of an investor, owner, vendor or other data subjects. For the purposes listed above, Merit is relying on performance of a contract necessity and legitimate interests.

SHARING PERSONAL INFORMATION

Merit does not disclose your personal information to third parties, except as described in this Notice, and never for compensation. Additionally, we will not share any Personal Information with third parties without your specific consent or unless Merit is required or permitted to by law (such as Regulation S-P) and/or by government authorities.

Examples of third parties with whom we may share your personal information include, but are not limited to:

  • Authorized service providers who perform services to facilitate your transactions with Merit, such as administrators, accountants, auditors, attorneys, tax advisors, payroll agents, insurance brokers, entities assessing our compliance with industry standards, brokers or custodians, payment processing, printing and mailing companies, email delivery, and other similar services;
  • A third party in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stocks; and
  • Government authorities in order to comply with appropriate laws and/or requests.

Third parties with whom we share Personal Information are required to maintain the confidentiality of such information and are prohibited from using your personal information for purposes other than those that were specified upon receipt of your data. We enter into contractual agreements with all nonaffiliated third parties that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.

If we share your Personal Information with third parties performing services for us, or acting on our behalf, we will contractually require them to protect your Personal Information.

SECURITY MEASURES

Merit restricts access to Personal Information to those employees who need to know that information to provide services in connection with Merit’s business. Merit has physical, electronic and administrative safeguards in place to help protect data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Some features of our information security program are:

  • A dedicated group of information security personnel that design, implement and monitor Merit’s information security program;
  • The use of firewalls and other specialized technology;
  • Continuous monitoring of our information and technology systems infrastructure to detect weaknesses and potential intrusions;
  • A combination of internal and external reviews of our Internet sites and services;
  • Implementing controls to identify, authenticate and authorize access to various systems or sites; and
  • Providing Merit personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

RETENTION OF PERSONAL INFORMATION

We will retain Personal Information for the period necessary to fulfill our services and the purposes outlined in this Notice unless a longer retention period is required by law. To determine the appropriate retention period for Personal Information, Merit will consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

MANAGING YOUR PERSONAL INFORMATION

If you would like to request, delete, or update the Personal Information that you provided us, or exercise any of your data protection rights, you may contact us using the contact information below. For your protection, we will need to verify your identity prior to complying with your request. Merit does not charge for this service.

Merit will make a good faith effort to process your request without undue delay and within the timeframe provided by applicable law. You are also entitled to have Merit modify or delete any information that you believe is incorrect or out of date. Merit reserves the right to limit or deny access to Personal Information where providing such information would be unreasonably burdensome or expensive or as otherwise permissible under relevant laws. If Merit determines that access cannot be provided in any particular instance, Merit will provide the individual requesting access with an explanation of why it has made that determination and a contact point for any further inquiries.

PERSONAL INFORMATION TRANSFERRED FROM THE UNITED KINGDOM, THE EUROPEAN UNION OR EUROPEAN ECONOMIC AREA

Personal Information may be transferred outside of the Cayman Islands, the United Kingdom (“UK”), the European Union (“EU”) or European Economic Area (“EEA”) to Merit servers in the United States. The General Data Protection Regulation (“GDPR”) was adopted by the EU to protect the privacy of such Personal Information for all EU individuals. After the UK left the EU, the UK substantially retained the EU GDPR in domestic law as the UK GDPR (here referred to together with the EU GDPR as simply “GDPR”) to continue to protect the privacy of such personal information for all UK individuals as well.

With respect to the collection, holding, storage, use, and processing of your Personal Information, Merit will:

  • Process the data lawfully, fairly and in a transparent way;
  • Obtain the information only for valid business purposes and not use it in any way that is incompatible with those purposes;
  • Collect only information that will be relevant to the purposes we have told you about and limited only to those purposes;
  • Take reasonable steps to ensure that the information is accurate and kept up to date;
  • Maintain the data only as long as necessary, subject to applicable legal or other requirements; and
  • Use appropriate technical and administrative measures to ensure appropriate security of the data.

Where your Personal Information is processed by third parties outside the EU, EEA or UK, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law.

We do not use computer algorithms to make automated decisions based on your personal information pursuant to the GDPR. We may process some of your personal information automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations to combat money laundering, terrorism financing, and offenses that pose a danger to assets.

RIGHTS OF PERSONS DOMICILED IN UK, EU AND EEA

Under the GDPR, persons domiciled in the UK, EU or EEA have certain rights with respect to their Personal Information. In particular, you may have the right to:

  • Request access to your personal information;
  • Ask to have inaccurate data amended;
  • Ask to have your personal information deleted;
  • Withdraw your consent to the processing of your personal information;
  • Request the prevention or restriction of processing of your personal information for any purpose; and
  • Request transfer of personal information to a third party when feasible.

You have the right to receive your Personal Information that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller without hindrance from us.

Additionally, in circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless required by law. EEA and UK residents may also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or, as the case may be, other competent supervisory authority of an EU member state.

RIGHTS OF PERSONS DOMICILED IN CALIFORNIA

Under the California Consumer Protection Act (“CCPA”), persons domiciled in California have certain rights with respect to their Personal Information. In particular, you may have the right to:

  • Request that we disclose, free of charge, the categories and specifics of the Personal Information we collect about you as a California resident (and/or, if applicable, disclose to a third party for business purposes).
  • Choose to opt-out of the sale of Personal Information. Currently, however, Merit does not sell Personal Information.
  • Request that we delete the Personal Information we have collected. Following our verification of the request, we will comply with the request and delete any or all of the Personal Information in our possession that we collected from you and/or any or all such Personal Information in the possession of our service providers, unless otherwise restricted by law or regulation. However, withdrawing your consent for us to collect, process, use, transfer and store your data may impact the services Merit provides to you as an owner of royalties or other mineral interests, or as an investor in our funds.

Merit follows the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights under the CCPA. However, withdrawing your consent for us to collect, process, use, transfer and store your data may impact the services Merit provides to you as an owner of royalties or other mineral interests, or as an investor in our funds.

WHERE THIS NOTICE CAN BE ACCESSED

This Notice is accessible through our website: https://meritenergy.com.

USE OF COOKIES ON MERIT’S WEBSITE, OWNER PORTAL AND INVESTOR PORTAL, AND OTHER SITES

Merit uses various technologies to collect information, including Personal Information, automatically on https://meritenergy.com. For example, in order to measure the usefulness and efficiency of our site, we automatically track certain information from all visitors to our site. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.

Additionally, like most interactive web sites, we use “cookies” on certain pages of our site. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain Personal Information, accessible to our site. These technologies help us recognize you, customize your experience on the site and analyze your use of the site to make them more useful to you. By visiting our site, you agree to our use of cookies.

You can refuse the use of cookies by selecting the appropriate browser setting. If you opt-out, please note that your experience using the site may not be optimal, and you may not be able to use certain features on our site.

CONTACT US

If you have questions, concerns, or suggestions related to our Notice or our privacy practices, contact Merit’s Chief Compliance Officer:

Merit Energy Company
13727 Noel Road, Ste. 1200
Dallas, Texas 75230

Websites: https://meritenergy.com/

Email Address: meritlegal@meritenergy.com

Phone Number: 972-701-8377

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this Notice at any time to reflect changes in our policies concerning the collection and use of personal information. The revised Notice will be effective immediately upon posting to our web site. As required by regulations, Merit will annually provide its investors with a statement regarding their rights to privacy.

This Privacy Notice was last revised and posted in October 2025.