Soul New Energy ("SNE", "we", "us" or "our") values your personal data and privacy. This Privacy Policy explains what information we may collect when you visit this website, submit a form, contact us, purchase Digital Products, engage our Services, or use third-party tools connected with this website; where that information comes from; how we use it; when it may be shared with or processed by third-party service providers; and how you may make requests concerning your personal data.

This Policy applies to this website, our request review forms, purchase flows, communications with us, and the reasonable technical and operational arrangements connected with those Services.

This Policy does not, on its own, govern refunds, license scope, content identification system rules, or general service termination arrangements. Those matters should be read with the Terms and Conditions and the Licensing and Custom Service Terms.

We may collect the following categories of personal data:

2.1 Contact Information

For example, your name, email address, phone number, social account contact details, or any other contact information you choose to provide.

2.2 Submission Information and Creative-Related Information

For example, stories, relationship background, personal experiences, project instructions, intended use, reference directions, preferences, target audience information, brand materials, and other related materials that you provide during a request review, commissioning discussion, or collaboration process.

2.3 Transaction and Order Information

For example, purchase records, payment status, order numbers, the type of Product or Service involved, delivery information, refund or support records, and basic administrative information connected with a transaction.

2.4 Technical and Usage Information

For example, IP address, device information, browser type, basic website usage logs, traffic source information, error logs, and other technical information required to operate the website or understand how it is used.

2.5 Communications Information

For example, enquiries, replies, support messages, email correspondence, project communications, and other records of interaction between you and us.

The information described above may come from the following sources:

• information you provide directly, such as when you complete a form, send us an email, submit a request, or communicate with us;
• information generated automatically when you use this website, such as basic technical logs, device information, and website usage data; and
• information provided to us by third-party platforms connected with this website, to the extent necessary for form submission, payment, order processing, or delivery.

We collect and use relevant information primarily for the following purposes:

• to respond to enquiries, review requests, arrange follow-up communications, and manage basic service workflows;
• to process purchases, confirm payment, provide delivery, follow up on orders, and offer reasonable customer support;
• to read and understand the stories, background, intended use, and creative direction you provide so that we can assess suitability and arrange appropriate next steps;
• to operate the website, maintain platform security, troubleshoot technical issues, and improve the overall user experience;
• to retain necessary transaction and project records for enquiries, disputes, prevention of misuse, or compliance with applicable legal requirements; and
• where you have separately agreed, or where applicable law permits, to handle specific notifications or communications that you have chosen to receive.

Processing that is reasonably necessary to handle your enquiry, order, delivery, support, the basic security of the website, or the retention of necessary records will generally be treated as necessary to provide the Product or Service you have requested. If you do not provide the relevant information, we may not be able to complete the relevant review, transaction, delivery, or support.

Where non-essential analytics, additional notifications, third-party embedded services, or direct marketing are involved in future, we will describe them separately where appropriate and, where required, provide you with relevant choices or obtain your consent.

We do not sell or rent your personal data.

Because SNE's Services may involve personal stories, relationship background, private experiences, and creative instructions, we handle such content with particular care and only to the extent reasonably necessary.

Unless there is a practical need to do so for one or more of the purposes below, we do not actively request sensitive information beyond what is reasonably necessary:

• reviewing a request and deciding whether it is suitable for us to take on;
• understanding the creative direction and collaboration arrangements;
• performing the confirmed Service or delivery; and
• dealing with administrative, dispute-related, or compliance matters connected with the engagement.

The story content, personal background, or identifiable information you submit will not automatically be made public for testimonials, portfolio use, case studies, or other public showcase purposes merely because you have submitted a form, purchased a Product, or engaged a Service.

If identifiable content, specific project information, full story content, excerpts of a work, or client identity is to be used publicly, this will generally be addressed through the relevant service terms and case-specific written arrangements.

To provide website, form, payment, delivery, communication, and basic technical functions, we may use third-party service providers to process certain information on our behalf. Based on our current service setup, these may include:

• Tally, for request review forms, form submissions, or other information collection;
• Payhip, for processing payment, order handling, or delivery for certain Digital Products;
• email and communication tools, for receiving enquiries, replying to messages, or handling administrative notices; and
• website hosting, content delivery, and media delivery providers, for hosting, media asset delivery, and core technical operations.

These third parties will only process information to the extent necessary for the services they provide. If we engage other processors to assist in handling personal data, we take reasonable contractual or other measures to require them to protect such information as applicable.

We may also disclose or transfer relevant information to the extent necessary where required by law, for the protection of rights, for dispute handling, in connection with a business transfer or restructuring, or for platform or service security.

This website may use cookies or similar technologies to support basic website functions, maintain security, record necessary session information, or improve the user experience.

7.1 Essential Functions

Certain technical elements may be necessary for the basic operation of the website, such as page loading, asset delivery, basic security mechanisms, or the normal functioning of an external checkout page.

7.2 Non-Essential Tools

If, in future, this website uses non-essential analytics tools, tracking tools, third-party embedded content, or other non-essential technologies, we will provide notice where appropriate and, where required, offer relevant choices or obtain your consent.

7.3 External Checkout Pages and Third-Party Pages

If you proceed from this website to a third-party payment page, media player, external form, or other third-party service, the cookies, technical records, and data processing connected with that service may also be governed by that third party's own policies and settings.

We retain personal data only for as long as is reasonably necessary to fulfil the purposes described in this Policy, comply with applicable legal requirements, keep reasonable transaction records, handle enquiries, deal with disputes, prevent misuse, or protect the legitimate interests of both parties.

Retention periods may vary depending on the nature of the information, transaction status, service progress, project needs, and applicable legal requirements.

When the information is no longer required for the original purpose or a directly related purpose, we will, where reasonably practicable and permitted by applicable law, take appropriate steps to delete it, anonymise it, or cease retaining it.

Because we may use service providers or infrastructure located outside Hong Kong, the information you provide may be processed, stored, or transferred outside Hong Kong. The level of protection for personal data may differ across jurisdictions.

Where reasonably practicable, we will seek to use suitable providers and take reasonable steps to safeguard information processing. However, we do not make guarantees as to outcomes beyond matters within our actual control.

We take reasonable and practicable steps, having regard to the nature of the data, the risks involved, and technical feasibility, to protect the personal data we hold against unauthorised or accidental access, processing, loss, use, or disclosure.

However, no internet transmission, third-party platform, or method of electronic storage can be guaranteed to be absolutely secure.

Subject to applicable law and reasonable identity verification, you may make reasonable requests concerning your personal data, including to:

• ask whether we hold personal data about you;
• request correction of inaccurate or incomplete information;
• request updates to your contact details or preferences;
• where applicable, withdraw consent previously given for certain non-essential processing;
• where applicable, require us to cease using your personal data for direct marketing; and
• where permitted by applicable law, reasonably practicable, and not inconsistent with our legal obligations, retention requirements, fraud prevention needs, or dispute-handling needs, request deletion of certain information.

We may need to verify your identity first, and, to the extent permitted by applicable law, we may reasonably limit or explain why we cannot fully comply with a request.

Nothing in this Policy grants an unconditional right to make any particular data request. Where we are required to retain information for legal, dispute-related, anti-abuse, transaction-record, or other legitimate purposes, we may keep the information that is necessary for those purposes.

Unless we have separately explained the relevant use for direct marketing purposes and, where required, obtained your consent, we do not currently use your personal data for general direct marketing.

If you have previously agreed to direct marketing, or if applicable law otherwise permits us to send you such communications, you may still ask us to stop. We will handle that request within a reasonable scope.

This website may contain links to third-party websites, platforms, or services. The privacy practices of those third parties are not governed by this Policy. When you leave this website or use a third-party service, you should review that third party's own privacy policy and terms.

We may update this Privacy Policy from time to time to reflect changes in our Services, technology, legal requirements, or operational needs. The updated version will be posted on this page and will take effect upon posting. Where a change is material, we may provide additional notice where appropriate.

If you have any questions about this Privacy Policy, your personal data, or any matter relating to our handling of information, you may contact us at:

• Email: hello@soulnewenergy.com