This Personal Data Protection Policy is formulated under the provisions of the Personal Information Protection Law of the People’s Republic of China, the Cybersecurity Law of the People’s Republic of China, and other applicable laws and regulations, and applies to the official website established and operated, and the accommodation and other services offered to, by HUTTOPIA in the People’s Republic of China.

The collection, processing, and transfer of certain user’s personal data (hereinafter referred to as “Personal Data”) are necessary for HUTTOPIA’s provision of accommodation and other services to user (hereinafter referred to as the “Service”) before or after a business contract is signed. user’s denial or objection to such collection, processing, and transfer of Personal Data may affect user’s access to HUTTOPIA’s Services. As such, when user requests or agrees to the provision of Services by HUTTOPIA or uses HUTTOPIA’s official website, user voluntarily acknowledges and consents, where required under applicable law, to the collection, use, processing, and transfer of his/her Personal Data by HUTTOPIA as follows:

1. HUTTOPIA will collect, hold, and process certain Personal Data about user, including but not limited to user’s name, home address, telephone number, date of birth, identification number, e-mail, and nationality for the exclusive purpose of providing the Services requested or agreed by user . Personal Data may be provided by user or collected from HUTTOPIA, its Affiliates, and/or third parties in compliance with applicable laws and regulations. HUTTOPIA will strictly abide by the principles of lawfulness, legitimacy, necessity, and good faith when collecting, holding, and processing user’s Personal Data, and take necessary security protection measures in line with industry-standard to protect user’s Personal Data.

2. HUTTOPIA provides accommodation and other relevant services for mainly adult customers. HUTTOPIA does not accept minors under the age of 14 who are not accompanied by adults. If HUTTOPIA has collected or may collect Personal Data of minors under the age of 14, HUTTOPIA will take stricter security protection measures and manage the data by category to prevent unauthorized access, divulgence, falsification, or loss of data, and HUTTOPIA will delete such data as quickly as possible.

3. HUTTOPIA will share and transfer Personal Data internally within HUTTOPIA Group within the territory of the People’s Republic of China as necessary for the purpose of completing the booking, taking a series of preparation measures before signing the contract, and performing the Services under relevant contracts. For these purposes, HUTTOPIA may further transfer Personal Data to any third parties within the territory of the People’s Republic of China that HUTTOPIA may engage to assist with the implementation, operation, and management of the Services under relevant contracts from time to time, including but not limited to HUTTOPIA’s partners, vendors (especially online payment vendors), and its holiday camps. user hereby authorizes the foregoing processing and transfer of Personal Data.

4. Meanwhile, user is fully aware that HUTTOPIA has the right to collect and process his/her Personal Data under the following circumstances without obtaining his/her consent:

I. where it is necessary for the conclusion and performance of a contract to which user is a party;

II. where it is necessary for HUTTOPIA to perform its statutory duties or statutory obligations;

III. where it is necessary for HUTTOPIA to respond to public health emergencies, or to protect the life, health, and property safety of natural persons in an emergency;

IV. where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of Personal Data is within a reasonable scope;

V. the processing of Personal Data disclosed by user or other legally disclosed Personal Data within a reasonable scope in accordance with law; and

VI. other circumstances prescribed by laws and administrative regulations.

5. Personal Data collected and generated by HUTTOPIA in the People’s Republic of China will be stored within the territory of the People’s Republic of China. If it is necessary to provide Personal Data overseas, HUTTOPIA will inform user of the overseas recipient’s name, contact information, purpose, and method of processing, type of Personal Data, and the method and procedure for user to exercise his/her legal rights against the overseas recipient, and will obtain user’s separate consent.

6. User may at any time exercise user’s rights provided under the provisions of applicable law, including his/her legal right to:

I. restrict or refuse the collection, processing, and/or transfer of Personal Data;

II. view, verify, and/or copy Personal Data;

III. request the correction, supplementation, amendment, and/or deletion of Personal Data, and

IV. withdraw consent to the collection, processing, or transfer of Personal Data as provided hereunder. user may seek to exercise these rights by contacting HUTTOPIA via the following method: send an e-mail to HUTTOPIA will respond within 3 days after receiving the request from user to exercise the foregoing rights.