This Privacy Policy explains how Soul New Energy Limited ("SNE", "Soul New Energy", "we" or "us") collects, uses, stores and handles information when you browse our website, submit a project for review, use creative services within Dream Workshop or Custom Song, or take part in registration, notification, follow-up or operational processes supported by Production Studio. Different services involve different types of information, and we process information only where it is relevant to the stated purpose.

Certain submission pages or service workflows may include a more specific privacy notice. Those notices supplement this Policy. Where a specific notice applies to a particular processing activity, that notice will govern that activity.

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.

Depending on which service you use, we may collect the following types of information:

2.1 Project Review & Contact Information

We may collect your name, email address and contact details, together with information submitted for project review, such as the type of project, objectives, intended use, timing, references, background information, submitted content and attachments.

2.2 Dream Workshop Creative & Delivery Information

If you use Dream Workshop or Custom Song, we may process information needed for creation and delivery, including stories, relationship context, personal experiences, creative direction, intended use, preferences, target audience, brand information, website copy, logos, images, event or campaign information, client files, reference materials, and records of revisions, approvals and delivery.

2.3 Production Studio Operational Information

Where Production Studio supports an event, course or other operational workflow, we may process registration and contact records, event or project identifiers, registration, payment or confirmation status, consent and communication preferences, email and reminder status, follow-up records, contact history, case progress, reconciliation records and other operational information needed to keep the workflow running.

2.4 Transaction, Technical & Communication Information

We may also process purchase or payment status, order or transaction identifiers, product or service type, delivery, refund and support records; as well as IP address, device and browser information, website usage, referral or source information, error records, and enquiries, replies, emails and project communications 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.

For non-essential analytics and advertising measurement tools, this website currently uses Google Analytics, Meta Pixel and Metricool; details and the control options available to you are set out in the "Cookies, Analytics, Embedded Content and External Checkout Pages" section below. As for additional notifications or direct marketing, if these are actually involved in future, we will describe them separately where appropriate and provide relevant choices where required.

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.

Unpublished stories, personal background information, brand materials, website content, images, client files, event or campaign information, and registration, contact or operational records provided to SNE do not automatically become public promotional material merely because you submit a project, purchase a service, commission creative work, provide materials, or use a workflow supported by Production Studio.

If we wish to use identifiable material in a testimonial, portfolio, case study, social media post or other public presentation, we will obtain appropriate permission or rely on an arrangement that has been clearly agreed between us.

To provide website, form, 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:

• Google Workspace (Google Sheets), for storing and managing your submitted request review form, case, and contact information;
• Cloud database services (Google Cloud Firestore), for storing submission records, case and contact information, and status or records required for certain operational workflows;
• Cloudflare Turnstile, for detecting and blocking automated abuse. To provide this function, Cloudflare processes IP addresses and browser- and connection-related signals, but does not read the contents entered into the form;
• automation and workflow services: in certain workflows, we may use automation services, including Make, for downstream notifications, status synchronisation, retries and other workflow operations;
• AI-assisted tools: certain internal workflows may use AI-assisted tools to organise or summarise information, or to generate email or text drafts. These tools are used to support internal workflows. We limit the information provided according to the relevant purpose and review outputs as appropriate before use;
• 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 currently uses cookies and similar technologies to support the basic operation of the website, understand how visitors use the website, measure the effectiveness of content, promotions and advertising, and improve our services. Some cookies are necessary for website operation, while others are used for non-essential analytics and advertising measurement purposes. You may block or delete cookies through your browser settings. For details of the non-essential analytics and advertising measurement tools currently used by this website, and the available control options, please refer to Section 7 of this Privacy Policy.

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 Analytics and Advertising Measurement Tools

To understand how visitors use this website, measure the effectiveness of our content, promotions and advertising, and improve our services, this website currently uses the following non-essential analytics and advertising measurement tools. These tools may set cookies or similar technologies, and may transmit certain usage data, device data or website interaction data to the relevant third parties:

• Google Analytics (GA4): used to analyse website traffic and usage behaviour, and may set Google Analytics-related cookies, such as _ga or other similar cookies;
• Meta Pixel: used to measure advertising effectiveness, build advertising audiences, conduct remarketing or similar advertising measurement activities, and may transmit certain interaction data from this website to Meta Platforms, including Facebook and Instagram, as well as set Meta-related cookies, such as _fbp or other similar cookies; and
• Metricool: used to analyse website traffic, content performance and social media-related performance.

The use of Meta Pixel for remarketing or similar advertising purposes refers to advertising measurement, audience creation and ad delivery optimisation within Meta Platforms' advertising systems. It does not mean that we use your contact details to send you general direct marketing communications. Unless otherwise stated in this Privacy Policy, or unless we separately provide you with relevant information, we do not use your name, email address, phone number or other contact details to send you direct marketing communications merely because you have visited this website.

You may control or refuse these non-essential cookies and related tracking by blocking or deleting cookies through your browser settings, installing the Google Analytics Opt-out Browser Add-on, or adjusting your advertising preferences in your Meta account settings. Please note that these third parties may process data in accordance with their own privacy policies, cookie policies and account settings. You may also review the privacy and advertising preference controls provided directly by the relevant third parties.

7.3 External Checkout Pages and Third-Party Pages

Where a service uses a third-party payment, checkout or transaction page, that provider will process information you submit to it under its own policies. We will generally receive only the status and transaction information needed for completion, delivery, reconciliation or support.

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:

Data handling and contact entity

• SOUL NEW ENERGY LIMITED
• Business Registration No.: 79188635-000-11-25-9
• Room 1603, 16/F, Trendy Centre, 1 Mei Wan Street, Tsuen Wan, Hong Kong
• Email: hello@soulnewenergy.com