Privacy Policy

Privacy Policy for Soneium

Last Updated: [2025-January]

This Privacy Policy sets out how Sony Block Solutions Labs Pte. Ltd. , of 105 Cecil Street＃24-02 The Octagon Singapore 069534 ("Sony", "we", "our" or "us") collects, uses, stores and otherwise processes Collected Data (defined below) in relation to the use of our blockchain services called "Soneium"(collectively, "Service")]. Sony will operate a Layer 2 ("L2") blockchain based on Ethereum as part of its Service. It also describes your data protection rights, including the right to object to some of the processing which Sony carries out. More information about your rights, and how to exercise them, is set out in Section 8 "Privacy Rights" below.

Please note that the Service provides access to services, sites, technology, applications and resources that are provided or otherwise made available by third parties ("Third-Party Services"). When you access and use Third-Party Services which are not governed by this Privacy Policy and our Terms of Service, their own terms of conditions, privacy policies or other agreements with such third parties will govern your use of such Third-Party Services.

Table of Contents

1. Definition
2. What personal data we collect
3. Why we process personal data
4. With whom we share Collected Data
5. Where we transfer Collected Data
6. How long we retain your personal data
7. Children
8. Privacy Rights
9. Changes to this Privacy Policy
10. Contact Information

1. Definition

1.1 "Collected Data" has the meaning set forth in Section 2 below.

1.2 "Sony Group Company" means Sony Group Corporation, which is the ultimate parent company of Sony and any legal entities controlled by Sony Group Corporation (the term "control" in this context means the direct or indirect ownership of at least fifty percent (50%) of the voting interest in such corporation or the power in fact to control the management decisions of such entity).

1.3 "Service Provider" means any third party who processes personal data on behalf of Sony, including but not limited to hosting providers, analytics service providers and customer support providers.

2. What personal data we collect

Sony collects data as described below, which may include personal data, (collectively, the “Collected Data”) directly from you or indirectly through other Sony Group Companies and/or third parties, if any. For the purposes of the GDPR and other applicable data protection laws and regulations where the concepts of "Controller" and "Processor" are defined, Sony is the “Controller” of the Collected Data.

2.1 Data collected directly from you

2.1.1 IP address

<Collection method>

• Sony collects the above information automatically when you use the Service.

2.1.2 Additional information you submit to us

Information you provide us including response to the survey, information submitted to participate in campaigns and your inquiries to us.

• <Collection method>
• If you contact us, Sony collects any information you provide through communication. Also Sony may ask you whether you would like to participate in a survey.

2.2 Data collected indirectly from other Sony Group Companies and/or third parties

Publicly Available Blockchain Data ("Blockchain Data")

<Collection method>

• Sony may collect public blockchain data including timestamps or events, transaction IDs, digital signatures, transaction amounts and wallet addresses.

Other Information available on internet including handle name, user generated contents, information related to campaigns and community activities on Discord or other third-party platform.

<Collection method>

• Sony may search and collect information related to our business on internet and may communicate with you, organize or support online activities on third party communication platform.

Please note that information relating to your use of the Services will be recorded on a public blockchain. A public blockchain is a decentralized, open and permissionless network that allows anyone to participate in its activities and is intended to record transactions across a wide range of computer systems. Public blockchains may be open to analysis which can lead to information relating to your use of the Services to be combined with other data which may reveal your information.

Sony does not intentionally collect special categories or sensitive data.

3. Why we process personal data

3.1 Sony processes your Collected Data for the purposes as described below. For these purposes, Sony may use Collected Data in conjunction with the information collected through other Sony Group Companies’ products and services if you use one of those.

Purpose of Use	Category of Collected Data	Legal Basis
Provision of functions and/or services of the Service To deliver functions and/or services you have asked us to provide to you. This includes making necessary notifications and providing software updates.	Collected Data listed in Section 2.1.-2.2	We have a legitimate interest to deliver the functions and/or the Services only on a test basis with you, to check if any improvement are needed or any bugs are to be fixed.
Enhancement of our products, services and business based on statistical data To analyse your use of the Service in order to improve and develop Sony Group Companies’ products, services and business.	Collected Data listed in Section 2.1.-2.2	We have a legitimate interest in understanding how our products and services are used, to learn what business strategies are effective and to improve them.
General marketing and communication Sony will use your personal information to answer your inquiries and communication with you.	Collected Data listed in Section 2.1.-2.2	We have a legitimate interest in collecting information available online about our business, responding your inquiries and have general communication with you on communication platform.
Protecting the interests of Sony Group Companies and users To protect Sony Group Companies’ business interests and legal rights and the interests and legal rights of our users. This includes the use of Collected Data in connection with legal claims, compliance, regulatory, auditing, investigative purposes (including disclosure of such information in connection with legal proceedings or litigation).	Collected Data listed in Section 2.1.-2.2	We have a legitimate interest in protecting Sony Group Companies’ business interests and legal rights, and the interests and legal rights of our users.
Compliance with law To respond to requests from and, where required, report content to government or public authorities, law enforcement officials, courts, regulators or similar in accordance with our legal and regulatory obligations under applicable laws.	Collected Data listed in Section 2.1.-2.2	When we have a legal obligation under EU/UK laws: We process Collected Data in order to comply with applicable law and regulations. When we have a legal obligation under laws outside the EU/UK: We have a legitimate interest in protecting Sony Group Companies’ business interests and legal rights, and the interests and legal rights of our users.

3.2 Where we collect the Collected Data to perform a contract with you, or where we have to collect Collected Data by law, provision of this data is mandatory and we will not be able to provide services to you without this information. In all other cases, provision of any requested Collected Data is optional, but not providing information may affect your ability to use the services or use particular aspects of the services if information is needed for those purposes.

3.3 There are instances where we have a legitimate interest to use the Collected Data. Our legitimate interest will vary depending on what we are using the Collected Data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process the Collected Data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.

4. With whom we share Collected Data

Sony shares your Collected Data with the following entities.

Entities with whom we share Collected Data	Detail
Sony Group Companies	We share Collected Data with Sony Group Companies where those companies process it on our behalf to provide products and services to you. If we have your permission, we also share Collected Data under the following categories with Sony Group Companies for them to send you marketing materials or survey requests. <Categories of Collected Data> [2.1.-2.2]
Service Providers	We share Collected Data under the following categories with Service Providers, including Sony Group Companies. <Categories of Collected Data> [2.1.-2.2]
Linked Third Party services	When you use third party services that are linked through our Service, the providers of those services or product will receive information about you. <Categories of Collected Data> [2.2]
Government authorities, law enforcement officials, regulators, and court and similar	We may share some or all Collected Data under the following categories with government authorities and/or law enforcement officials if required by law, or if necessary for us to protect our legitimate interests, or the interests of others, in compliance with applicable laws. <Categories of Collected Data> [All information listed in Section 2]
Counterparty of Business transfer	In the event that we undertake a merger, acquisition, reorganization or disposal, some or all Collected Data under the following categories may be disclosed to any prospective purchaser and/or its advisers and will be passed to the new owners of the business. <Categories of Collected Data> [All information listed in Section 2]
Professional advisors	In some cases, if this is necessary for the purposes listed above, we may share some or all Collected Data under the following categories with professional advisers including lawyers, auditors, or insurers. <Categories of Collected Data> [All information listed in Section 2]

5. Where we transfer Collected Data

We will process, store and transfer Collected Data for the purposes outlined in this Privacy Policy from your country/regions of residence globally to countries/regions outside your country/region of residence. Collected Data will be processed by staff operating outside your country/region of residence who work for us or for one of our Service Providers. Some of the countries and regions may not provide the same level of data protection as your country.

For EEA/UK Individuals: Sony takes appropriate measures to ensure that all transfers of Collected Data outside of the EEA/the UK meet the requirements of applicable EU and UK data protection legislation.Where information is transferred outside the EEA and the UK, where the privacy laws may not provide an equivalent level of protection to those in your home country and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission or the UK Government, the personal data is adequately protected by the vendor's EU / UK Processor Binding Corporate Rules, the EU Commission’s approved standard contractual clauses which can be accessed here or the addendum to the EU Commission’s standard contractual clauses or standalone international data transfer agreement approved under UK data protection law (as applicable). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

Please note the once it is recorded on the blockchain, the data may be accessed and retrieved by anyone around the world.

6. How long we retain your personal data

6.1 We retain Collected Data (except Blockchain Data) for as long as we continue to make the Service available to you.

6.2 Due to the technical nature of blockchain technology, it is not possible to delete Collected Data once recorded on the blockchain.

6.3 If there is a claim or a potential claim, or if we are required to retain information by law then we will keep the data for so long as is reasonably necessary for this.

7. Children

Sony is committed to complying with all applicable laws and regulations regarding the collection, storage and use of Collected Data concerning children. The Service is not directed to and does not knowingly collect Collected Data from children. Depending on your country/region of residence, this threshold age for a child may differ. If you are a parent or guardian and are concerned that your child has provided us with Collected Data without your consent, you should contact us as indicated in Section 10 "Contact Information" below.

8. Privacy Rights

8.1 In some countries, you have the following rights with respect to Collected Data Sony processes about you:
  (1) Ask us for a copy of Collected Data
  (2) Ask us to correct, delete or restrict our processing of Collected Data
  (3) Request us to transmit some Collected Data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible
  (4) Object to our processing Collected Data on the basis of our legitimate interests (or those of a third party)
  (5) Where we have asked for your consent, to withdraw consent at any time. If you ask to withdraw your consent, this will not affect any processing which has already taken place at that time.

8.2 To the extent required by applicable laws, you can exercise these rights by contacting us as indicated in Section 10 “Contact Information” below. These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

8.3 These rights may also be limited due to the technical nature of blockchain technology. For example, it will not be possible to delete, correct or modify all records of your personal data once recorded on the block chain.

8.4 If you have unresolved concerns, you have the right to complain to a data protection authority in the country where you live, work, or where you believe a breach has occurred. Details of EU data protection authorities are available here. and the website of the data protection authority of the UK Information Commissioner’s office is here and the website of the Personal Data Privacy Commission of Singapore is here.

9. Changes to this Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (if necessary under applicable law) of any changes to this Privacy Policy.

10. Contact Information

10.1 The data controller for Collected Data is Sony Block Solutions Labs Pte. Ltd. , of 105 Cecil Street＃24-02 The Octagon Singapore 069534. If you have any questions or concerns about this privacy policy or if you wish to exercise any legal right you have in respect of Collected Data, you can contact from here.

11. ADDITIONAL NOTICES - US STATE RIGHTS

Notice to Residents of States with Comprehensive Privacy Laws (other than California):

We set forth above in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.

Residents of certain U.S. states may have the following rights with respect to their personal data subject to the meanings and exceptions set forth in applicable state comprehensive privacy laws:

1. To confirm whether we are processing your personal data, as defined in applicable state laws (hereunder, "Personal Data"), and request to access such data.
2. That we correct inaccurate Personal Data we hold about you.
3. That we delete the Personal Data provided by you or obtained about you.
4. To obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability.

If you are a resident of one of these states and would like to exercise any of these rights, please complete the form here: Data Requests. These rights are limited due to the technical nature of blockchain technology. For example, it is not possible to delete or correct your Personal Data once recorded on the blockchain.

Rights Request Appeals

Pursuant to applicable state laws, if, for any reason, you would like to appeal a decision made by us relating to your request, you have the right to submit an appeal and can do so by completing this form: Data Requests. Please include your full name, the basis for your appeal, and any additional information to consider.

Notice to California Residents

This California Privacy Notice is effective as of [2025.1.14].

This California Privacy Notice supplements our Privacy Policy and applies only to California residents. This notice sets forth the disclosures and rights for California Consumers regarding their personal information, as required by the California Privacy Rights Act and any implementing regulations adopted thereunder ("CPRA"). Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CPRA, unless otherwise defined.

Personal Information We Collect & Purposes for Collection

The Personal Information we collect about you will depend upon how you use the website or otherwise interact with us. Accordingly, we may not collect all of the below information about you. In addition to the below, we may collect and/or use additional types of information but will only do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CPRA.

We may have used Personal Information for the following business or commercial purposes: 

Categories of Personal Information Collected	Business or Commercial Purposes for Collection of Personal Information	Categories of Sources from Which Personal Information Was Collected	Categories of Third Parties to Whom We May Disclose Personal Information for a Business Purpose
Identifiers such as name, phone number, mailing address, email, and online or device identifiers such IP address	To provide requested services; respond to your inquiries; maintain and improve our products and services; monitor and maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	Consumers; Sony Group companies;	Sony Group companies; Service Providers;
Internet or Other Electronic Network Activity such as computer and connection information, browser type, operating system	To maintain and improve our products, services and features; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	Consumers; Sony Group companies;	Sony Group companies; Service Providers; Legal Authorities (as required by law); Business Transfer Recipients.
Inferences Drawn from Other Information and Consumer Characteristics such as demographics, interests or hobbies, and inferences drawn from collected information.	To develop, maintain and improve the products, services and features offered by us and the Sony Group companies	Consumers; Sony Group companies	Sony Group companies; Service Providers; Legal Authorities (as required by law); Business Transfer Recipients.

Data Retention

We retain all categories of Personal Information described in this California Privacy Notice (except blockchain data) for as long as it is reasonably necessary for the purposes outlined in this California Privacy Notice, considering the time period reasonably necessary to: provide the Services; exercise the choices and rights you have requested; comply with our contractual obligations; comply with applicable legal, regulatory, or other obligations; including litigation holds and agency regulations. Due to the technical nature of blockchain technology, it is not possible to delete Personal Information once recorded on the blockchain.

California Consumer Rights

Subject to certain exceptions, as a California consumer, you may have the following rights regarding your Personal Information:

• Request to Know. Request information regarding what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you
• Request to Delete. Request deletion of the Personal Information we collect about you
• Request to Correct. Request correction of inaccurate Personal Information that we maintain about you
• "Do Not Sell or Share My Personal Information." Request to opt-out of the “sale” of your Personal Information or the “sharing” of your Personal Information to a third party for cross-contextual behavioral advertising (i.e., targeted advertising). We do not sell or share for cross-contextual behavioral advertising Personal Information (including Personal Information associated with individuals under the age of 16) collected via the Services, so this right is not applicable.
• "Limit the Use and Disclosure of Sensitive Personal Information." Under the CPRA, we must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer or does not fall under certain statutory exceptions. Sony's use and disclosure of Sensitive Personal Information is not used for such purposes and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.

When you use the Services, you are directing Sony to record information related to your use of the Services on a public blockchain. These rights are limited due to the technical nature of blockchain technology. For example, it is not possible to delete or correct your Personal Data once recorded on the block chain.

Verifying Requests. In your request, you must provide enough information to allow us to verify you are the person about whom we collected Personal Information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it. We can't respond to your request if we can't verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.

We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with additional information in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

Agents. If you are an authorized representative submitting a request on a consumer's behalf, please complete the applicable fields of information in the submission form. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and a clear description of the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. The consumer's identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer's behalf, we may deny the request.

Exercising your Rights

Right to Know; Right to Delete; Right to Correct

If you are a California Consumer and would like to exercise your Right to Know, Right to Delete, and/or Right to Correct, please submit your request at: Data Requests; or email us. For requests to know, in order to have us provide specific pieces of information, we will require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

California Consumers have the right to not receive discriminatory treatment for exercising CPRA rights. We will not discriminate against you for exercising your CPRA rights.

Notice of Financial Incentive

Under California regulations, if we offer certain loyalty or similar program(s) directly or reasonably related to the collection, retention or deletion of your Personal Information, such program may be considered a "financial incentive." In such case, we will be required to make additional disclosures to you, which we will provide when you agree to participate.