FIVE EXPERTS

Privacy Policy

Effective Date: [Insert Date]
FiveX Holdings, Inc., a Delaware corporation (“Five Experts,” “Company,” “we,” “us,” or “our”).

This Privacy Policy explains how we collect, use, disclose, and protect Personal Information in connection with the Five Experts platform and related services (the “Services”), including commercial diligence, investor support, expert matching, and value creation engagements.

This Policy applies to:

• Experts
• Investors (including searchers, independent sponsors, and private equity firms)
• Portfolio companies and sell-side companies
• Website visitors and users

By using the Services, you agree to this Privacy Policy.

---

1. Categories of Information We Collect

A. Information You Provide

We collect Personal Information when you:

• Create an account
• Apply to join as an Expert
• Book or participate in commercial diligence
• Engage in Day 1 or 90-day planning
• Participate in Years 1–5 value creation initiatives
• Communicate with us

This may include:

Personal Identifiers
Name, email address, phone number, mailing address, company name, job title, and similar identifiers.

Professional & Deal Information
Background, experience, deal participation, transaction details, diligence materials, and strategic planning inputs.

Financial & Payment Information
Billing information and transaction data required to process payments through Stripe or other payment providers. We do not store full credit card numbers.

Engagement Materials
Information shared in CIMs, diligence reports, investor materials, planning documents, and related communications.

---

2. Recorded Sessions & Engagement Data

In alignment with our Expert Terms:

We may record video sessions, advisory calls, diligence discussions, and related communications for:

• Quality assurance
• Dispute resolution
• Compliance and risk management
• Internal training

Participation in such sessions constitutes consent to recording where legally permitted.

Engagement materials and communications may be stored as part of our business records.

---

3. Automatically Collected Information

We collect Usage Information, including:

• Device and browser data
• IP address
• Page views and navigation activity
• Time spent on pages
• Referring URLs
• Approximate location (IP-based)

We use cookies and similar technologies to maintain platform functionality and improve performance.

---

4. How We Use Information

We use Personal Information to:

• Operate and improve the Five Experts platform
• Match Experts with investors and companies
• Facilitate payment processing (including the 15% platform fee structure)
• Support commercial diligence and value creation engagements
• Maintain records related to introductions and ongoing engagements
• Enforce our Expert and Client Terms
• Prevent fraud and protect platform integrity
• Comply with legal obligations

We may also use de-identified or aggregated data for internal analysis and business development.

---

5. Information Sharing

We do not sell Personal Information.

We may share information with:

Service Providers

Including Stripe (payment processing), cloud hosting providers, analytics services, communications vendors, legal advisors, and compliance partners.

Clients & Experts

To facilitate introductions, engagement scoping, and execution of agreed services.

Affiliates

Entities under common ownership or control.

Business Transfers

In connection with mergers, acquisitions, financing due diligence, restructuring, or asset sales.

Legal & Compliance

If required by law, subpoena, court order, or to enforce agreements.

---

6. Payment Processing & Platform Fee Structure

In alignment with our Expert Terms:

All payments related to platform introductions must be processed through approved payment processors.

We collect and retain transaction records necessary to administer the 15% platform fee and maintain compliance with our contractual obligations.

Payment data is processed in accordance with Stripe’s security standards. We do not store full card numbers.

---

7. Data Retention

We retain Personal Information:

• As long as necessary to provide Services
• To enforce non-circumvention and contractual terms
• To comply with legal and tax obligations
• To resolve disputes

We may retain anonymized or aggregated information indefinitely.

---

8. Privacy Rights

California Residents (CCPA/CPRA)

You may have the right to:

• Know what Personal Information we collect
• Request deletion
• Request correction
• Limit certain data uses
• Not receive discriminatory treatment

We do not sell Personal Information under California law.

Requests may be submitted to: hi@fiveexperts.com

We may verify identity before responding.

Nevada Residents

We do not sell Personal Information for monetary consideration as defined under Nevada law.

---

9. Data Security

We maintain administrative, technical, and physical safeguards designed to protect Personal Information.

However, no system can guarantee absolute security.

---

10. International Transfers

Five Experts operates in the United States. Information may be transferred to and processed in the United States and other jurisdictions where we or our service providers operate.

---

11. Children’s Privacy

The Services are not intended for individuals under 18.

We do not knowingly collect Personal Information from children under 13.

---

12. Updates to This Policy

We may update this Privacy Policy periodically.

Material updates will be reflected with a revised Effective Date.

Continued use of the Services constitutes acceptance of the updated Policy.

---

13. Contact

Questions regarding this Privacy Policy may be directed to:

hi@fiveexperts.com