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Privacy Statement

Dear customers:

Wanda hotels and Resorts is committed to providing a high level of customer service, including respecting your privacy and protecting your personal information. The privacy and security of your information is extremely important to us. We want you to know in real time how we use your relevant information when you visit our website, book hotel rooms, and become a member of our loyalty program. We also want you to trust the way we manage this information. The purpose of preparing this privacy statement is to further explain how we collect and manage your information and obtain your authorization to provide you with relevant services, as well as your choice of how we use your information.

In accordance with the personal information protection law of the people's Republic of China, in this Privacy Statement ("statement"), we provide you with detailed information about how we collect, use and disclose your personal information.

This statement applies to Wanda hotels and resorts and Wanda managed hotels.

By using any of our products or services and / or agreeing to this statement, for example, in the process of registering any of our products or services, you understand and confirm that we will collect and use personal information as described in this statement. Please note that this statement does not apply to our personal information processing on behalf of or in accordance with the instructions of third parties, such as airlines, car rental companies and other service providers, companies that organize or provide travel arrangement packages, marketing partners or corporate customers.

1. Personal data acquisition

We will collect your personal information directly from you, collect information about you from other individuals / entities / online channels, and automatically collect your personal information when you use our website, Wanda brand digital channels, and certain products or services (such as wireless networks) provided by Wanda hotels and resorts. We will provide more details in the following sections. In particular, we will collect and use your information if you (or others acting on your behalf) book accommodation in Wanda hotels and resorts through the reservation department, participate in loyalty programs, or interact with us through our company website or other Wanda brand digital channels. You do not need to provide personal information when using our website; However, in some cases, without your personal information, we may not be able to provide services to you (for example, we may not be able to complete the reservation you requested or let you join our reward program). To learn more about how we collect, use and share your information and how to opt out, please click on the relevant sections below.

We will collect your personal data according to law at every link of the guest's journey so as to provide you with better services. Personal data is your personally identifiable data or identifiable personal data related to you. We collect and process your personal data in the following categories:

• name

• gender

• mailing address

• telephone number

• email:

• financial information (such as credit card, debit card number or other payment data)

• language preferences

• date of birth

• nationality, passport, visa or other identity data issued by the government

• important dates: birthdays, anniversaries and special occasions

• member or frequent flyer program data (including travel partner program participants)

• employer information (for enterprise related bookings)

• travel route, tour group or activity data

• previous accommodation or interaction of guests, purchased goods and services, special services and convenience requirements

In rare cases, we may also collect:

• data on family members and peers, such as children's names and ages

• biometric data

• image and audio and video data obtained through the following equipment: security cameras located in public areas of the hotel (such as corridors and lobbies)

In order to meet your needs or provide you with considerate services (such as special meals), we need to collect sensitive information such as race or ethnicity, political views, religious and philosophical beliefs, whether to join a trade union, health or sexual orientation details. In this case, we will only collect information with your prior express consent.

If you submit any personal data about other people to us or our service provider (if you book for other people), you have obtained corresponding authorization and you allow us to use such data in accordance with this privacy statement.

We may collect personal data in various situations, including:

1. Hotel activities:

• book a room;

• check in and payment;

• hotel accommodation and services provided during the stay;

• spend in the hotel's bar or restaurant during the stay;

• requests, complaints and / or disputes.

2. Participate in marketing plans or activities:

• sign up for the customer loyalty program;

• participate in customer surveys (e.g. customer satisfaction surveys);

• subscribe to newsletters to receive offers and promotions via email.

3. Forward information from a third party:

• tourism operators, travel agencies (online or offline), GDS reservation systems, etc;

4. Network activities:

• log in to the website of Wanda hotels and Resorts (cookies specified in the IP address and privacy statement);

• online information collection form (online booking, questionnaire).

2. Legal basis for processing your personal data

We undertake to collect and use your information in accordance with applicable data protection laws.

We will collect, use and share your information only when there is an appropriate legal basis.

This may be because:

• you have agreed to our use of your personal information;

• we need to use your information to fulfill the contract we signed with you, for example, according to the terms of the agreement we reached with you, complete and manage your booking, and operate and provide services related to our loyalty program for you;

• we need to use your information to fulfill our responsibilities to regulators, tax officials, law enforcement agencies, or to fulfill our legal responsibilities;

• our use of your information is in line with our legitimate interests as a business institution, such as operating and improving our services, and letting people know about our products and services (including analysis and targeted advertising). In these cases, we will always protect your information in a proportionate manner and respect your privacy rights, and you have the right to refuse to process your information.

If you want to know more about the legal basis for our processing of personal information, please contact us (please refer to the "how to contact us" section for details). If you have agreed to our processing of your information, you can contact Wanda hotels and resorts at any time to revoke this consent (please refer to the section on how to contact us for details).

3. Personal information protection

Wanda hotels and resorts promises to protect the confidentiality and security of the information you provide us. To this end, we have developed technical, physical and organizational security measures to protect against any unauthorized access, disclosure, damage or loss of your information. The collection, transmission and storage of information cannot guarantee absolute security, but we take measures to ensure that appropriate security defenses are in place to protect your information. To this end, we have taken a series of technical measures (such as firewalls) and organizational measures (such as user ID / password system, entity prevention measures, etc.) to ensure that the system and data processing services are long-term confidential, complete, easy to use and recover.

Wanda hotels and Resorts has a strong team composed of specialized information security professionals to manage the security plan of Wanda hotels and resorts. The team is responsible for monitoring whether our system has potential intrusion, responding to potential incidents, supporting information security work at the hotel level, regularly reviewing and updating the security control used by Wanda hotels and resorts to protect data, and providing training procedures for information security of Wanda hotels and resorts.

We require third parties sharing personal information with us to make reasonable efforts to maintain the confidentiality of personal information.

We will never ask you to send us confidential personal information or payment card information via email or SMS.

In case of security incidents, Wanda hotels and resorts will notify the regulatory authorities and / or users in accordance with the requirements of applicable laws and regulations.

If you have reason to believe that your interaction with us is no longer safe (for example, you feel that the security of your account has been reduced), please inform us immediately according to the contact information provided in the "contact us" section below.

4. International information transmission

When we operate through the global network of the company's offices, reservation and service centers, data centers and hotels, we may need to transmit your information to China, where the headquarters of Wanda hotels and Resorts is located. For example, the information we collect on the following aspects: booking or staying in hotels owned by Wanda hotels and resorts, joining the loyalty program of Wanda club Interact with us via email or other digital channels. Information provided during booking or through any other service can be transmitted to any affiliated entity and hotel of Wanda hotels and resorts in China for implementing or improving these services. We also need to transmit this information to other entities, including but not limited to our Wanda hotels and Resorts' hotels, partners and service providers.

If we transmit information from countries / regions other than China to Chinese Mainland, we will take measures to ensure that such transmission is carefully managed to protect your privacy rights:

• the internal transmission of hotels under Wanda hotels and resorts must comply with the agreement (intra group agreement) signed by members of hotels under Wanda hotels and resorts, which stipulates that every member must ensure that your information is fully and consistently protected when transmitting information within hotels under Wanda hotels and resorts;

• if we transfer your data to other companies other than Wanda hotels and resorts, including companies providing services to us, we will obtain contractual commitments and guarantees from such companies to protect your information. Some of these guarantees are recognized certification plans, such as standard contract terms;

• we will only transfer personal information to countries / regions that are considered to provide an appropriate level of legal protection, or countries / regions where we can be confident that there are other arrangements to protect your privacy; also

• before disclosing personal information, any information request we receive from law enforcement or regulatory agencies will be carefully verified.

In other cases, when we transmit personal information in different jurisdictions, we will take measures according to the requirements of local laws to ensure that such transmission is managed, so as to protect your privacy rights.

5. Disclosure in accordance with legal obligations or to protect the safety of personnel and property

Wanda hotels and resorts will disclose personal information according to legal requirements. Examples of such disclosure include: when the state requires Wanda hotels and resorts to collect personal data about hotel visitors in that country, when law enforcement agencies provide effective subpoenas to Wanda hotels and resorts, and when civil litigants provide legal evidence disclosure requests to Wanda hotels and resorts. Wanda hotels and resorts can choose to share necessary personal information with law enforcement agencies or others to protect the safety and security of people and property, seek available relief measures or limit the damage we may suffer, and respond to emergencies.

6. Cookies and other data

What is a cookie: "cookie" refers to a small text file stored in a web browser or device of a web user, which is used to remember and obtain the user's information. You will be assigned a cookie when you visit our website or other electronic channels. Cookies can sometimes be used for certain e-mail activities where permitted by applicable law.

We collect specific data through cookies, which are directly stored on the computer or mobile device you use. We collect data through cookies, such as: browser type, online service visit duration, historical web pages visited, relevant URLs, language preferences, and other aggregated traffic data.

Functional cookies: these cookies are used to support the use of websites and applications and to implement certain functions to improve the user experience. For example, we use functional cookies to help you make reservations and remember your choices on different pages. We also remember your login information and hotel preferences through functional cookies, so that you do not need to enter them again.

Performance cookies: these cookies can collect information to support the website and applications, help us improve the website, and discover any problems you encounter when browsing us. For example, performance cookies can provide us with information about how you enter our website and how you navigate within the website when browsing. We also use these cookies to provide us with data and analysis information, such as how many visitors the website has or how our advertising works.

Targeted cookies: – these cookies are used to collect your information, improve our products and services, and provide you with targeted advertisements that we think are relevant to you. We use targeted cookies in our websites and applications to carry out a variety of marketing and activities.

Third party advertising: when you visit and use the group's online services or other websites, we may place advertisements through third-party advertising companies for goods and services that you may be interested in. For such advertisements, these companies will place or identify unique cookies on your browser (including the use of pixel codes).

Other data

Your browser or device: we automatically collect specific data through your browser or through your device, such as: your Mac address, computer type (windows or apple), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the online service you use. We use the above information to ensure the normal operation of online services.

Pixel tags and other similar technologies: we will collect data through pixel tags (also known as network beacons and clear gifs), which may be used in some online services to track the behavior of online service users (including email recipients), judge whether our marketing activities are successful, and compile statistics on the use of online services.

Your IP address: we will collect your IP address, which is a set of numbers automatically assigned by your network service provider (ISP) for the device you are using. No matter when the user accesses the online service, the IP address will be automatically identified and recorded in our server log file, as well as the web page visited and the access time. We use IP addresses for the following purposes, such as calculating usage, diagnosing server problems, and managing online services. We may also obtain your approximate location through your IP address.

7. Use unlimited network

When you use the wireless network service of Wanda hotels and resorts, we may collect and process some additional information.

Information we collect

Registration and information provided by users:

When you use the wireless network services of Wanda hotels and resorts, we may collect personal information about you, including your last name, Wanyue Club account number, room number and other personal information (such as mobile phone number) required by your location and applicable laws.

Device identifier: in the process of providing the wireless network of Wanda hotels and resorts, we may automatically collect the device identifiers of computers, mobile devices, technologies or other devices used for wireless network access (such as your IP address, MAC address, device name or other unique identifiers). The device identifier is a number that is automatically assigned to the device when you visit the wireless network of Wanda hotels and resorts. We may identify the device through the device identifier. When you use Wanda hotels and resorts unlimited network, we may check your device identifier and use this information to improve our service. We may associate your device identifier with your other information, such as your Wanyue club member account.

Other device information: we may also automatically record some information in your device, including the type of device, the web page, application or site you visit, and the date and time (Internet activity information) when you visit, enter or use the infinite network of Wanda hotels and resorts. Although such information is usually anonymous and / or aggregated, this information may be associated with your Wanyue club member account number and / or persistent identifier. This data helps to manage our network and provides us with the use information of the unlimited network of Wanda hotels and resorts. However, we will not collect and process the contents of e-mails or other electronic communications you send or receive when using the wireless network of Wanda hotels and resorts.

Location information: when you use Wi-Fi service in the hotel, we will collect your location information through it, so as to improve the quality of our service and provide you with services such as customized discounts and promotional activities.

8. Data retention period

For the reasons explained in this privacy policy, we will generally only retain your information for a reasonable period of time. In some cases, if necessary, we will keep the transaction records (which may contain your information) for a long time to meet legal, regulatory, tax or accounting needs. In addition, we will retain information where we reasonably believe that litigation may occur. We comply with the data retention policy and apply it to the records we hold. When we destroy your personal information, our approach is to prevent the information from being recovered or reconstructed.

9. Links to other websites

Our websites and applications contain links to websites maintained and / or controlled by non related parties. In some cases, these websites can carry out brand association and display our logo or other trademarks. You can check the uniform record locator ("URL") on the page you are visiting to determine whether you are visiting our website. We recommend that you check the privacy policies of these non affiliated websites, because their privacy policies may be different from ours.

10. Services for children and minors

Our website is not open to children, and we will not intentionally solicit or collect personal information of minors under the age of 18. If we are informed or found that the personal information of minors has been improperly collected, we will take commercially reasonable measures to delete such information. In a few cases, we may launch promotion programs for children. In such cases, the terms and conditions of the relevant promotion plan will contain details of the relevant information processing.

11. Changes to the privacy statement

In some cases, we may change, modify or amend the privacy statement to meet the changing regulatory environment or business needs. Unless otherwise notified by applicable laws, any changes to this privacy statement will be notified through our website. However, if the change will cause the use of your personal information to be different from the instructions when collecting information, we will take appropriate measures to notify you, such as publishing a notice on our website 15 working days before the change takes effect, or notifying you by e-mail. If required by applicable laws, we will obtain your consent when making changes.

12. Contact us

1) If you have any questions, comments or suggestions about this privacy policy or related matters of your personal information, please send an email to Callcenter@wandahotels.com 。

2) Normally, we will reply within 15 days. If you are not satisfied with our reply, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also seek solutions through the following external channels:

a. File a civil lawsuit with the people's Court of the place where the defendant is located;

b. Report to the central information technology office (the website of the reporting center is: http://www.12377.cn , reporting telephone: 12377)

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