Privacy Policy - Meanwhile

By accessing this website or using Meanwhile's products or services, you consent to the processing of your personal information (referred to herein as "Personal Information" or "Personal Data") as described in this Privacy Notice.

This Privacy Policy applies to:

Meanwhile Incorporated
Meanwhile [BTC Private Credit Fund] GP
Meanwhile BTC Private Credit Fund LP
Meanwhile Advisors LLC
Meanwhile Insurance Bitcoin (Bermuda) Limited
Meanwhile Insurance USD (Bermuda) Limited
Meanwhile Identity (Bermuda) Limited
Meanwhile Services (Bermuda) Limited
Meanwhile (Bermuda) Limited

collectively, "Meanwhile", and was last modified in December 2025.

We reserve the right to update this Privacy Notice and related policies at any time and as may be prudent or necessary to reflect changes in our privacy practices or legal requirements.

This Notice provides an overview of how Meanwhile's Privacy Policy and how we may collect, use and protect personal information belonging to anyone that interacts with us including clients, business partners or other third parties in our global business activities.

This Notice applies when you connect with Meanwhile through any communication channels. We also provide more detailed information about your interactions with us when you visit our website ("Digital Properties").

Meanwhile will only use fair and legal means to collect your information and we will only use it in a legal, respectful and fair manner. Meanwhile complies with the Bermuda Personal Information Protection Act 2016 ("PIPA") as well as the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA").

Personal Information

Personal Information or Persona Data as defined by PIPA and CCPA means information about an identifiable individual. This includes factual or subjective information from which an individual's identity can be reasonably determined. It also includes data points that when combined with other information could identify an individual. This may be your contact, health, financial or lifestyle information, or feedback you provide through surveys. It does not include aggregate or anonymous data because that information does not identify an individual.

What Personal Information might we collect from you

Meanwhile collects, uses and discloses only the Personal Information and Sensitive Personal Information about you that may be necessary to:

deliver our products and services;
enhance your experience and interactions with us;
manage our business operations;
fulfil our legal and security obligations.

Meanwhile will not sell or otherwise commercially exploit your personal information, nor do we use it for any third-party marketing purposes.

Meanwhile maintains appropriate procedures to ensure that Personal Information in our possession and the information we exchange with our service providers and agents is accurate and kept up to date. As permitted by applicable law, you can request to access and correct your Personal Information.

Meanwhile conducts Privacy Impact Assessments ("PIAs") for new business initiatives and any significant changes to processes that involve Personal Information. The PIA is a strong risk management practice that helps us protect your privacy when we collect, use and share Personal Information.

Types of information, including Personal Information, we might collect and use

Meanwhile may collect and use Personal Information that you provide to us to identify you, or that may make you identifiable, and may include:

Personal identification information, such as full name, date of birth, passport (and all related information therein), government issued identification, driving licence or other photographic identity details;
IP address, information related to any potential politically exposed person status or other information about you that is in the public domain;
Company or organization details, including business or personal contact information including residence, nationality, postal address, email address and any telephone number(s);
Professional and employment information (which may include your level of education, professional qualifications, employer's name and details of directorships or other offices you may hold);
Demographic information such as postcode, preferences and interests, association or professional affiliations or memberships;
Financial information, including sources of wealth, existing or previous wills or estate information, your assets, existing banking details and credit history;
Information pertinent to fulfilling our legal services on an individual's or organisation's behalf, which may include criminal records, media reports, regulatory records about you from regulators either within or outside of Bermuda, police records or other security related information; and,
Information we collect automatically through cookies and similar tracking technologies through our website.

Meanwhile may also collect, store and use the following "special categories" of more sensitive personal information including:

Racial or ethnic origin;
Political opinions, religious or philosophical beliefs;
Trade union membership;
Data concerning physical or mental health or disabilities;
Genetic data or biometric data for the purpose of uniquely identifying a natural person;
Data relating to any criminal allegations, criminal records, regulatory records, court cases and convictions;
Marital or family status; or
Data concerning a natural person's sex life or sexual orientation

How we use your Personal Information

Meanwhile may use the Personal Information that we collect for the following purposes, where legally necessary and appropriate:

To respond to your enquiries;
To understand your needs and suitability of our products;
To process and evaluate an application, transaction, or request related to life insurance, annuity, investment account, or other product or service we may offer (any of which referred to here for convenience as "your policy");
To underwrite an application for your policy;
To administer claims and determine or fulfill responsibility for coverage and provision of benefits;
To administer coverage, benefits, and other features provided by your policy;
To obtain reinsurance;
To manage your accounts and provide administrative support;
To coordinate the provision of our products or services with our suppliers or service providers;
To investigate and respond to complaints;
To confirm your identity to make sure no one else is accessing your Personal Information without authorization;
To enhance digital security including preventing and detecting security threats and unauthorised activities;
To implement risk management programs and procedures to protect against fraud, errors or misrepresentations;
As may be required for any legal or regulatory purposes, including but not limited to those associated with our due diligence Anti-Money Laundering and Anti-Terrorism Financing, or other "Know Your Customer" requirements or governance practices;
To maintain our list of contacts;
For Meanwhile's business purposes, including operational and administrative matters, improving the provision of our legal services; for data analysis, including client analytics; submitting invoices; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
To analyze and improve our internal business processes;
To develop products and services;
To determine effectiveness of our marketing and advertising;
To evaluate and improve the functionality of our Digital Properties;
To measure engagement and gain a better understanding of client behaviours on our Digital Properties;
To personalise and improve your experience while using our Digital Properties;
To better understand your preferences, needs and how you use our Digital Properties;
To display customised preferences (language, time zone, etc.) when you return to our websites;
To assess the effectiveness of our events, promotional campaigns and publications;
To evaluate and recruit personnel;
As Meanwhile believes reasonably necessary or appropriate to comply with our legal and/or regulatory obligations; to comply with our professional and ethical duties; respond to legal process or requests for information issued by courts, regulators, government authorities or other third parties; or, protect your, our, or others' rights, including legal rights; and
For any other legally permissible purpose related to your policy.

Meanwhile may need to use your Personal Information in other ways, as required by law. If we need to use your information for any other purposes, we will do so only with your consent.

When and why we might share your Personal Information

Meanwhile is responsible for protecting the confidentiality of all Personal Information in our possession. That includes information transferred to third parties performing services on our behalf such as our agents, service providers or our affiliates, along with our reinsurers. Unless prohibited by legal or contractual requirements, we and some of these third parties may store or process your Personal Information outside of the jurisdiction where it was collected. In those cases, Meanwhile follows all local laws, and the processing of your Personal Information may be subject to the laws of those other jurisdictions. Meanwhile always requires that these third parties protect your Personal Information consistent with our privacy policies and practices and comply with relevant laws.

Meanwhile is careful what information we share and why. We aim to limit the Personal Information we share with third parties to what is needed for the service they provide.

Here are some of the services third parties provide:

providing cloud hosted digital solutions and advanced technologies, IT support, security and consulting services;
supporting our administrative, underwriting and claims processes;
custodial services;
facilitating marketing campaigns, product promotion, surveys and market research activities.

Meanwhile will, or may, disclose your Personal Information to the following individuals and entities.

Other companies within the Meanwhile Group that provide support to Meanwhile's business purposes;
Employees of Meanwhile but their use shall be limited to the performance of their duties and in line with the reason for processing. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to provide legal services, to deal with requests which are submitted to us or for the purposes of facilitating our use of that information in accordance with this Privacy Policy.

The above list is not intended to be exhaustive and will be updated periodically. as and when the purposes, use and individuals to whom Personal Information will be provided change.

In some cases, laws require us to share information with regulators or government agencies.

What choices are available to you

Meanwhile will inform you why we collect, use and share your Personal Information. In some cases, we may request your express consent for the use of your Personal Information. You have a choice to withdraw your consent for processing of your Personal Information. Sometimes, this is not possible because of legal or contractual requirements. Withdrawing your consent may limit our ability to provide you with a full range of services. Here are some of the choices you may have depending on your jurisdiction:

You may request not to receive marketing and other commercial messages;
You may choose to communicate with us and provide your information using multiple channels: digital, telephone, fax or regular mail;
You have a number of options to manage cookies. If you choose to delete or refuse cookies, or choose not to share certain device information, some functionalities on our Digital Properties may not be available to you.

Requesting access to or limiting the use of your information

To obtain access to, or make a request for limiting the use of, correcting, blocking, erasing or destroying your Personal Information, please submit a written request to the Meanwhile e-mail address listed below. This request must include sufficient information to enable us, with reasonable effort, to identify the Personal Information that is relevant to your request. Your request must also include all necessary contact information for us to respond to your request and validate the identity of the requestor.

You will be contacted promptly by Meanwhile to confirm our receipt of your request.

Please submit written requests to the following email box:

privacy@meanwhile.com

Please note the following information associated with any request we receive from you:

We require your accurate and complete name and contact information;
We will promptly confirm our receipt of your enquiry or instructions within 48 hours;
We will take a reasonable amount of time to process your enquiry or instructions and respond to your request, but usually no more than 45 days (depending upon the nature and complexity of your request).

Meanwhile reserves all of its rights and protections afforded to it under PIPA, CCPA and CPRA.

Digital Properties

You do not have to provide Personal Information to use our Digital Properties unless a particular feature requires it. Meanwhile collects and analyze data related to your use of our Digital Properties to evaluate and improve functionality, user experience and the effectiveness of our advertising and marketing activities. We may combine some of the data we collect through our Digital Properties with other data we have about you for analytics.

Examples of the data we collect may include:

your IP address;
your device information such as your operating system, browser version and screen resolution;
your approximate location;
how you got to our Digital Properties (i.e. traffic sources); whether you are a new or repeat visitor;
what pages on our Digital Properties you view;
how long you stay on our Digital Properties;
what links you clicked on;
whether you viewed any videos;
what you search for on our Digital Properties;
information you have voluntarily provided through surveys and forms on our Digital Properties.

We improve your digital experience when we use this data to:

evaluate and enhance site performance, user experience and functionality;
gather insights that will help us improve our products and services;
make our content easier to find in both internal and external search engines.

Privacy Officer contact information

For inquiries or concerns regarding our handling and use of your Personal Information, please contact our Privacy Officer.

Privacy Officer: Alice Tregunna
Email: privacy@meanwhile.bm
Mail:

Meanwhile

Magnolia Towers

Second Floor Office Space

15 Parliament Street

City of Hamilton HM 12

Bermuda

Regulator contact information

Bermuda

Regulator: Office of the Privacy Commissioner
Email: PrivCom@privacy.bm
Phone: 441-543-7748
Mail:

Office of the Privacy Commissioner

Maxwell Roberts Building

4th Floor

1 Church Street

Hamilton, HM 11

Bermuda
Website: www.privacy.bm

United States

Regulator: California Privacy Protection Agency
Phone: 916-572-2900
Mail:

California Privacy Protection Agency

400 R Street

Suite 350

Sacramento, CA 95811

USA
Website: www.cppa.ca.gov

Meanwhile Privacy Notice & Policy