Privacy Policy

Privacy Policy for Soneium

Last Updated: September 29, 2026

This Privacy Policy sets out how Soneium Foundation, Cricket Square, Hutchins Drive, PO Box 2681, Grand Cayman, KY1-1111 Cayman Islands (the "Foundation", "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"). The Foundation 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 the Foundation carries out. The Foundation processes personal data in accordance with the Data Protection Act (2021 Revision) of the Cayman Islands (the "DPA") and, to the extent applicable, other data protection laws of the jurisdictions in which users of the Service are located. More information about your rights, and how to exercise them, is set out in Section 10 "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"), including third-party interfaces that may be displayed or embedded within the Service (for example, interfaces through which third parties offer their own digital assets). 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. Any information you enter into such third-party interfaces is collected directly by the relevant third party, not by the Foundation.

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. Cookies and Similar Technologies
8. Protection of Personal Data
9. Children
10. Privacy Rights
11. Changes to this Privacy Policy
12. Contact Information
13. ADDITIONAL NOTICES - US STATE RIGHTS

1. Definition

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

1.2 "Related Entities" means (a) any entity that the Foundation directly or indirectly controls (its "affiliates"); and (b) any entity that the Foundation engages or partners with for the operation of Soneium, and the affiliates of such entity (its "delegates").

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

1.4 "Email Distribution Service" means any third-party service used by the Foundation to send newsletters, email communications and other electronic messages.

2. What personal data we collect

The Foundation collects data as described below, which may include personal data, (collectively, the “Collected Data”) directly from you or indirectly through Related Entities and/or third parties, if any. For the purposes of the Data Protection Act (2021 Revision) of the Cayman Islands and other applicable data protection laws and regulations where the concepts of "data controller" and "data processor" are defined, the Foundation is the “data controller” of the Collected Data.

2.1 Data collected directly from you

2.1.1 IP address and other information collected automatically

<Collection method>

• The Foundation automatically collects the following information when you use the Service: IP address (including approximate location at a city level derived from your IP address); information about the device, operating system, and browser you use, and other device characteristics such as screen resolution and language settings; information about what you view or click on while using the Service and how you use the Service; diagnostic and troubleshooting information such as timestamps, error messages, and performance logs; and information from cookies and similar technologies (see the section "Cookies and Similar Technologies" below).

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, the Foundation collects any information you provide through communication. Also the Foundation may ask you whether you would like to participate in a survey.

2.1.3 Email address

<Collection method>

• The Foundation collects your email address when you subscribe to our newsletter or provide your email address for communications via our Email Distribution Service, together with information about whether you open or click the emails we send.

2.2 Data collected indirectly from Related Entities and/or third parties

2.2.1 Publicly Available Blockchain Data ("Blockchain Data")

<Collection method>

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

2.2.2 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>

• The Foundation 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.

The Foundation does not intentionally collect special categories or sensitive data.

3. Why we process personal data

3.1 The Foundation processes your Collected Data for the purposes as described below. For these purposes, the Foundation may use Collected Data in conjunction with the information collected through Related Entities’ 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. Under the DPA, this processing is necessary for the purposes of our legitimate interests, provided those interests are not overridden by your rights and freedoms.
Enhancement of our products, services and business based on statistical data To analyse your use of the Service in order to improve and develop Related Entities’ 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. Under the DPA, this processing is necessary for the purposes of our legitimate interests.
General marketing and communication The Foundation 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 responding to your inquiries and communicating with you. Under the DPA, this processing is necessary for the purposes of our legitimate interests.
Newsletter The Foundation will use your personal information to send you newsletter.	Collected Data listed in Section 2.1.	This processing is based on your consent, which you may withdraw at any time. Under the DPA, consent is a lawful basis for processing.
Organizing campaigns, contests, competitions and events, and rewards or points programmes, and supporting online communities The Foundation will use your personal information to organize campaigns and events, to operate rewards or points programmes (including calculating and allocating points based on your holdings and activity on Soneium), and support business development and online activities.	Collected Data listed in Section 2.1.-2.2	We have a legitimate interest in organizing campaigns, events and rewards or points programmes, and supporting online activities. Under the DPA, this processing is necessary for the purposes of our legitimate interests. Where we have a contract with you, this processing is necessary for the performance of a contract.
Protecting the interests of Related Entities and users To protect Related Entities’ 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 the Related Entities’ business interests and legal rights, and the interests and legal rights of our users. Under the DPA, this processing is necessary for the purposes of our legitimate interests.
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	Under the DPA: We process Collected Data in order to comply with a legal obligation to which the Foundation is subject, or where necessary for the purposes of our legitimate interests in protecting the Related Entities’ business interests and legal rights.

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 the DPA and other applicable 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.

4. With whom we share Collected Data

The Foundation shares your Collected Data with the following entities.

Entities with whom we share Collected Data	Detail
Related Entities	We share Collected Data with Related Entities 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 Related Entities 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 Related Entities. <Categories of Collected Data> [2.1.-2.2]
Linked Third Party services	When you use third party services that are linked through or embedded within our Service, the providers of those services or product will receive information about you. To distribute NFTs or to grant a role to you on third party platforms such as Discord we may require you to perform certain actions (e.g.; logging in to your account every day). In such cases we may share your personal data with such platforms to check that you have performed the required actions. Data processing on third-party platforms is subject to the privacy policies of those platforms. We are not responsible for the use, storage, or processing of data by such third-party platforms. <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.

Under the DPA, the Foundation will not transfer personal data outside the Cayman Islands unless adequate safeguards are in place to protect the data, including contractual arrangements that provide an adequate level of protection. Where the Foundation uses third-party service providers located outside the Cayman Islands (including in the United States), transfers are protected by appropriate contractual safeguards.

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. Cookies and Similar Technologies

7.1 Cookies are small text files placed on your device when you visit a website. We also use similar technologies such as local storage and pixels, which work in comparable ways. In this section, "cookies" refers to all of these.

7.2 We use cookies for the following purposes:

(a) Strictly necessary: essential for the Service to function and to keep it secure, including fraud and bot prevention. These cannot be switched off.

(b) Performance: to understand how visitors use the Service, including which pages are viewed, how visitors arrive, and how they interact with pages, so that we can improve the Service. We use third-party analytics services for this purpose. Where the Service offers cookie consent options, these cookies are used in accordance with your choice.

(c) Functional: to remember your preferences, such as your language setting.

7.3 Session cookies are deleted when you close your browser. Persistent cookies remain until they expire or until you delete them. You can delete cookies at any time through your browser settings.

7.4 How to manage cookies:

• Where the Service offers cookie consent options, you can use them to accept or decline performance cookies and to change your choice at any time.
• Most browsers allow you to block or delete cookies through their settings. Blocking cookies may affect how parts of the Service work.
• You can contact us as indicated in the section "Contact Information" below with any request relating to your data.

7.5 We may update this section as our use of cookies changes. The date of the most recent revision is shown at the top of this Privacy Policy.

8. Protection of Personal Data

8.1 The Foundation takes the security of Collected Data seriously and has implemented appropriate technical and organisational measures designed to protect Collected Data against unauthorised or unlawful processing, and against accidental loss, destruction or damage, in accordance with the DPA.

8.2 These measures include, as appropriate to the nature of the Collected Data and the manner in which it is processed: (a) encryption or other appropriate safeguards for Collected Data in transit and at rest; (b) restricting access to Collected Data to personnel and Service Providers who need it for the purposes described in this Privacy Policy; (c) guidance and instructions to personnel who handle Collected Data on their data protection obligations; and (d) periodic review of our security arrangements.

8.3 Where the Foundation engages Service Providers (as defined in Section 1.3), including entities that provide services on the Foundation’s behalf, and tools used in connection with our Email Distribution Service or for surveys and campaign management, to process Collected Data, the Foundation requires those Service Providers, by contract, to apply appropriate technical and organisational security measures consistent with the DPA and, where applicable, to notify the Foundation of any personal data breach without undue delay. This applies equally where a Service Provider is located outside the Cayman Islands, including in the United States, consistent with Section 5 “Where we transfer Collected Data” above.

8.4 No method of transmission or storage is completely secure, and the Foundation cannot guarantee the absolute security of Collected Data. You are responsible for safeguarding any account credentials, private keys, wallet software, devices or other access information within your control, and for your own use of the Soneium blockchain and any third-party applications. The Foundation is not responsible for any loss arising from your failure to do so, from the acts or omissions of any third-party wallet provider, node operator or other third party you choose to use, or from any compromise that is not attributable to the Foundation.

8.5 If the Foundation becomes aware of a personal data breach affecting your Collected Data, it will notify you and the Ombudsman without undue delay, in accordance with the timeframes and requirements of the DPA.

9. Children

The Foundation 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 12 "Contact Information" below.

10. Privacy Rights

10.1 Under the DPA and, where applicable, other data protection laws, you may have the following rights with respect to Collected Data the Foundation 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.

10.2 To the extent required by applicable laws, you can exercise these rights by contacting us as indicated in Section 12 “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.

10.3 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.

10.4 If you have unresolved concerns, you have the right to complain to a data protection authority. In the Cayman Islands, the supervisory authority is the Office of the Ombudsman, whose website is here. For EEA individuals, details of EU data protection authorities are available here. The website of the UK Information Commissioner’s Office is here.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Service, our processing of Collected Data, applicable law, regulatory guidance, or our operational requirements.

Where we make any material change to this Privacy Policy, we will take reasonable steps to notify you before the change takes effect or otherwise as required by applicable law. Material changes may include changes to the identity or contact details of the data controller, the categories of Collected Data that we process, the purposes for which we process Collected Data, the lawful basis or condition on which we rely, the categories of recipients with whom we share Collected Data, the countries or territories to which Collected Data is transferred, the safeguards used for international transfers, applicable retention periods, or your privacy rights.

We may notify you of material changes by appropriate means, which may include posting a notice on the website, updating the “Last Updated” date at the top of this Privacy Policy, sending an email or other direct communication where we have your contact details, or using any other notice method described in the Terms of Service.

If a change would involve processing Collected Data for a new purpose that is not compatible with the purposes described in this Privacy Policy, or if applicable law requires us to obtain your consent before applying the change, we will identify an appropriate lawful basis or condition for that processing and, where required, obtain your consent before processing your Collected Data for that new purpose.

Where we rely on your consent, you may withdraw that consent at any time using the contact details set out in Section 12 “Contact Information” below, without affecting the lawfulness of processing carried out before your withdrawal.

12. Contact Information

12.1 The data controller for Collected Data is Soneium Foundation, of Cricket Square, Hutchins Drive, PO Box 2681, Grand Cayman, KY1-1111 Cayman Islands. 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.

13. 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 September 29, 2026.

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; organize campaigns, contests, competitions and events; support online communities; send you newsletters; monitor and maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	Consumers; Related Entities;	Related Entities; 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; organize campaigns, contests, competitions and events; support online communities; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	Consumers; Related Entities;	Related Entities; Service Providers; Legal Authorities (as required by law); Business Transfer Recipients.
Information you have made publicly available online such as social media handles, content you have posted, information related to campaigns and community activities on third-party communications platforms	To maintain and improve our products, services and features; organize campaigns, contests, competitions and events; support online communities; monitor and help maintain security of our systems and prevent fraud; internal business, legal and compliance purposes	Consumers; Related Entities;	Related Entities; 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 Related Entities; organize campaigns, contests, competitions and events; support online communities	Consumers; Related Entities	Related Entities; 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. The Foundation'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 the Foundation 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 at support@soneium.org. 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.