Issued or Updated Date: 2024-08-15

STEY attaches great importance to user privacy and the protection of personal information. When using our products/services, we may collect and use your relevant information. To help you better understand how we collect, use, and protect your personal information, this “STEY Privacy Policy” (“Policy”) describes how we handle your information in different scenarios and explains how we collect, use, store, process, disclose, transfer, share, and protect your information on the STEY platform. It also helps you know how to query, access, delete, correct, and withdraw authorization of your personal information. Important content related to rights of your personal information is highlighted in bold.

This “Policy” is part of our “Terms of Service”. By using or continuing to use our services or accepting our “Terms of Service”, you allow us to use, store, process, disclose, transfer, share and protect your information in accordance with this “Policy”.

Note: We encourage you to read and understand this privacy policy carefully before using STEY and related services, so you can make appropriate choices.

Relevant Definitions:

1. STEY Platform: Refers to the webpage with the domain name stey.com and mobile clients (including mobile internet applications, WeChat Mini Programs, or H5 pages). The terminal devices applicable to clients include but are not limited to PCs, tablets, phones, TVs and so on.

2. “STEY”, “We”: Includes the developer and maintainer of the STEY platform, Beijing Side Information Technology Co., Ltd. (registered address: Room 205-52, 2nd Floor, Building 2, A1&A3, Qinglong Alley, Dongcheng District, Beijing), and the operator and manager of the STEY platform's related services, Beijing Jiuli Hotel Management Co., Ltd. (registered address: Room 205-51, 2nd Floor, Building 2, A1&A3, Qinglong Alley, Dongcheng District, Beijing), along with its enterprise groups including affiliated companies.

3. Sensitive Personal Information: Refers to personal information that could lead to discrimination or serious harm to personal or property safety if disclosed or used illegally, including but not limited to race, ethnicity, religious beliefs, identification numbers, personal biometric characteristics, medical and health information, financial accounts, personal travel, communication records and content, accommodation information, and information of minors under the age of fourteen. (Specific sensitive personal information will be prominently marked in bold within this statement).

4. Device Information: Includes device identifiers (IMEI, IDFV, Android ID, MAC, OAID and other device-related information), application information (app crash reports, notification status, app installation list, and other app-related information), device parameters and system information (device type, device model, operating system, and hardware-related information), and device network environment information (IP address, WiFi information, base station information, and other network-related information). All will depend on the actual collection of products.

5. Service Log Information: Includes browsing history, click and view history, search history, favorites, add to cart, transaction, after-sales service, shared information, published information, as well as IP address, browser type, telecom operator, language, access date, time, etc.

Table of Contents:

I. Information Collection and Use

II. How We Use Cookies

III. How We Share, Transfer, and Disclose Your Personal Information

IV. Storage of Personal Information

V. Your Rights to Manage Personal Information

VI. Protection of Minors

VII. Update to the Privacy Policy

VIII. How to Contact Us

I.Information Collection and Use

i.When you use our products and/or services, the personal information we need/may need to collect and use includes the following two types:

1. To achieve the basic functions of providing our products and/or services to you and fulfill the obligations stipulated by laws and regulations, you must provide us with or authorize us to collect and use necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. To provide you with additional functions of our products and/or services, you can choose to provide us with or authorize us to collect and use information. If you refuse to provide, you will not be able to use the relevant additional functions or achieve the intended functional effects, but it will not affect your normal use of the basic functions of our products and/or services.

ii.You understand and agree that we are committed to creating a diverse range of products and services to meet your needs. Due to the wide variety of products and services we provide to you, and the differences in the specific product/service scope chosen by different users, the basic/additional functions, and the types and scope of personal information collected and used may vary accordingly. Please refer to the specific product/service functions.

1. Browsing Function

Generally, after you agree to this privacy policy, you can search and browse various products/services on the STEY platform without logging in. In this case, STEY will not collect any information. But please understand that some information on the page may require you to register as a member and log in before you can browse for the purpose of protecting commercial information.

2. Registration and Management of Member Accounts

(1) Account Registration

If you want to use our products/services, you first need to register a member account and become our member. You understand and agree that all activities performed on the STEY platform using your STEY member account represent you personally. All electronic information records generated by operations of your STEY member account are valid proof of your actions and you are responsible for all consequences arising therefrom.

When you register for a STEY member account using a mobile number or one-click login, you need to provide at least a mobile number (to receive SMS verification codes or for identity verification) to create and log in to the account. You can register as a STEY member after reading and confirming this privacy policy.

The Geetest SDK (Software Development Kit) requires to obtain your device information during your registration and login to provide you with seamless local authentication, quick account login, device fraud risk identification, and cheating behavior verification services. For details, see the third article of this privacy policy.

If you refuse to provide a mobile number, you will not be able to create an account on the STEY platform and use its products/services.

(2) Member Information Maintenance and Account Management

Based on your account usage, the membership rules and account level calculation rules set by us, we will determine your current points and level, and provide you with the corresponding rights and benefits of the account points and level.

To enhance your online identity verification information, help us provide more personalized member benefit services, and improve service quality as reasonably needed, you can choose to provide a username, nickname, real name, gender, date of birth, marital status, hometown, school, company, industry, skills, etc.

To ensure transaction identification, your profile photo and community nickname will be displayed. We may also use your other information, including responses you send us during surveys.

3. Ordering and Order Management

When you prepare to book/order hotel services, our system will automatically generate the corresponding order for you. During the booking/ordering and order management process, we may collect the following information that you need to fill in by yourself or authorize us to help you complete, and we remind you, in the specific booking/ordering process, to pay attention to:

(1) Contact information you provide or notify (name, mobile number, email, etc.).

(2) Guest's name and mobile number, so that we and the hotel can provide you with information notifications, cancellations, and other subsequent services according to their respective responsibilities.

(3) Order information (hotel information, service information, check-in and check-out times, order number, order time, amount, order payment status, and other related information).

(4) Other services that require you to continue to provide necessary information to complete the booking/ordering are based on the prompts or authorized content during the booking/ordering process. Please read carefully.

We collect this information to help you to complete transactions smoothly, ensure your transaction security, query order information, manage order information, and provide customer service and after-sales services as well as other purposes we explicitly inform you of.

When you book a hotel or other products/services for others, you need to provide the personal information of the actual guest. You should ensure that you have obtained their consent before providing their personal information to us and that they are aware of and accept this policy. Our products and services are not provided to minors, so please do not book hotels or other products and services for minors.

4. Check-in and Related Services

（1）When you check in, we will legally collect information including your and other guests' identification documents, phone numbers, check-in and check-out times, room number, room rate, and other check-in details; pre-authorized credit card information and payment records. Additionally, to comply with the identity verification requirements of the public security authorities, we need to upload your identification document information and person-identification comparison information to the system designated by the public security authorities. We do not handle or store facial recognition information or person-identification comparison information.

（2）When you sign a long-term stay service contract, we will legally collect the name of the contracting party, types and numbers of identification documents, contact address, email address, identification document information of the guest, room number, room rate, check-in and check-out times, and emergency contact information.

If you choose to sign the electronic contract online, we will transfer the electronic contract along with your name, identification number, and phone number to our third-party partner, Hangzhou Tiangu Information Technology Co., Ltd. (eSign), to complete the real-name authentication and online signing process.

（3）During your long-term stay at STEY, we will collect and process information about the usage of water and electricity in your room to issue bills, ensuring you can enjoy our services properly during the stay.

（4）To comply with local regulatory requirements, the hotel may also need to collect information including your identification documents and device information. Please note that we collect such information to fulfill legal and regulatory obligations for identity verification and log retention. We may adjust the specific scope of information collection according to legal regulations or regulatory requirements.

5. Assisting with Payments

When you choose to pay your bill through third-party payment tools (WeChat, Alipay, ASIAPAY), we will share your STEY APP platform account, corresponding third-party payment account, order number, transaction time, transaction target, transaction bill, order transaction amount, order status, order security-related device information, name, phone number, email address, and other necessary information required by laws, regulations, or third-party payment institutions directly or via the third-party payment software toolkits (SDK) integrated into the STEY APP platform with third-party payment institutions. This is to complete the order payment settlement after verifying your real identity.

6. Customer Service and Dispute Resolution

When you contact our concierge or customer service for while-sales, after-sales communication, or dispute resolution (e.g., if you need assistance in querying order information), we may need you to provide necessary personal information to verify your real identity for account and system security.

To facilitate communication, promptly solve problems, or record corresponding handling and results, we will retain your communication/call records and related content with us (including other information you provide to prove related facts or contact information you leave). If you consult, complain, or provide suggestions regarding a specific order, we will use your account and order information.

7. Providing Security and Service Optimization

When you log in and use the STEY platform, to use our services properly and to maintain the normal and stable operation of the STEY platform, improve and optimize our service experience, ensure account security, prevent transaction risk, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analyzing, and handling measures as required by law, we have embedded the application security SDK developed by our partner Firebase-Crashlytics in the application program. This SDK collects and obtains your device information and user behavior data, as detailed in Article 3 of this policy.

8. Providing Functions of Information Publishing

When you choose to use the STEY platform’s events/sharing and other information publishing functions, including sharing and publishing text and images, posting reviews, and answering questions as a member, we will collect and save the content you publish, your searches, activities you participate in, as well as other information generated by other functions of STEY and you provide.

Please note that the information you publish may involve your or others' personal or even sensitive information. Please consider carefully whether to publicly share such information when using our services. If the published information involves minors' personal information, you must obtain the consent of the minor's guardian before publishing. In such cases, guardians have the right to contact us through the contact information provided in this privacy policy to request corrections or deletions of content involving minors' personal information.

9. Instant Messaging Service

If you choose to use the instant messaging services provided by STEY to communicate with other users on the STEY platform, your communication information will be transmitted in an encrypted manner. To ensure effective transmission and delivery, all your messages will be stored in STEY. You can choose to back up or delete communication records stored on the STEY platform.

10. Additional Services for Authorization Provision

(1) Camera/Video-based Additional Services

Once you enable camera/video permissions, you can use this function to take photos, upload, and share. Please be aware that even if you agree to enable camera permissions, we will access photo information through the camera only when you click the relevant icon within the app.

(2) Recording Permissions

To allow you to use the voice function in the chat, we need you to enable recording permissions in the system. Please note that even if you agree to enable recording permissions, we will access recording information through the recorder only when you click the relevant icon within the app.

(3) Additional Services for Image Access and Upload Based on Storage Permissions (including audio, video, and photo albums)

With photo album permissions enabled, you can upload your photos/images/audio and video for purposes such as changing your profile photo, communicating with your concierge, customer service, or other customers through instant messaging, and publishing or sharing content.

(4) Clipboard-based Verification Code Recognition and Pasting Function

When you choose to use your phone number to log in, we will access the clipboard permission to facilitate the filling in of the verification code after receiving the verification SMS on your phone. When you input text, we may read your clipboard to enable pasting and other functions.

(5) Notification Permissions

It is used to receive notifications from the STEY APP. To ensure you receive our messages even when the STEY APP is closed or running in the background, we need to use the auto-starting function. This involves sending broadcasts periodically through the system to wake up the STEY APP, which is necessary to provide certain functions or services. Specific auto-starting scenarios include: when you exit the STEY APP, the push SDK will monitor the system broadcast to implement message push/reminder functions for you, related but not limited to hotel and other information.

(6) You understand and agree that the above additional services may require you to enable camera, recording, storage (audio/video/photos), and application list access permissions on your device to collect and use the relevant information. You can check and manage these permissions in the settings of your device and can decide to enable or disable them at any time. Permissions are not enabled by default; they are only used when you explicitly authorize them for specific functions or services. You can also revoke authorization. It is particularly noted that even with your authorization, we will not collect information unless it is necessary for the relevant function or service.

Please be aware that enabling any permission means that you authorize us to collect and use relevant personal information to provide the corresponding services. Once you disable any permission, it means you cancel the authorization, and we will no longer collect or use the relevant personal information based on that permission and will not be able to provide the services associated with it. However, your decision to disable permissions will not affect the information collection and use based on your previous authorization.

11. Indirect Collection of Your Personal Information

If we indirectly obtain your information from third parties (e.g., your reservation information provided to our business partners for processing your order to ensure successful booking), we will clearly require the third party to have legally obtained your consent before collecting personal information and to inform you of the shared information content. Sensitive information must be explicitly confirmed by you before being used by us. We will require the third party to commit to the legality and compliance of the source of personal information, and if the third party violates this, we will clearly require them to bear the corresponding legal responsibilities. We will protect personal information obtained indirectly by using measures and protections no less than those used for our own users' personal information.

12. Others

(1) If the information you provide contains personal information of other third parties, you must ensure that you have obtained legal authorization before providing such personal information to us. If it involves the personal information of minors, you must obtain the consent of the corresponding minor's guardian before providing it. In such cases, the guardian has the right to contact us through the methods disclosed in this statement to request correction or deletion of the minor's personal information.

(2) According to applicable laws, if we take technical and other necessary measures to process personal information so that the data recipient cannot re-identify the specific individual and cannot restore it, or if we perform de-identification of the collected information for research, statistical analysis, and prediction to improve the platform's content and layout, provide product or service support for commercial decisions, and improve our products and services, the use of such processed data does not require further notification to you and your consent.

(3) If we use the information for other purposes not specified in this statement or use the information collected for specific purposes for other purposes, we will obtain your authorization and consent again.

(4) According to relevant laws, regulations, and national standards, the STEY platform may collect and use your personal information without seeking your authorization in the following situations:

a) Related to fulfilling obligations under national laws and regulations, and requirements from industry authorities;

b) Directly related to national security and defense security;

c) Directly related to public safety, public health, and significant public interests;

d) Directly related to criminal investigation, prosecution, trial, and execution of judgment;

e) For the purpose of safeguarding your or others' significant legal rights and interests such as life and property but it is difficult to obtain your own consent;

f) Personal information you have publicly disclosed;

g) Personal information collected from legal public disclosures, such as news reports and government information disclosures;

h) Necessary for signing and performing contracts based on your request;

i) Necessary for maintaining the security and stable operation of the services provided.

II. How We Use Cookies

1. In order to ensure an easier access, when you visit our STEY platform or use the services provided by us, we may identify you through small data files, which is designed to help you save the repeated step of entering your registration information or to help you determine the security of your account. These data files are Cookie files.

2. In addition to Cookies, we may also use other similar technologies on the STEY platform to collect information of activities you’re browsing through web beacons, pixels, and so on.

3. You can set your browser to disable cookies.

III. How We Share, Transfer, and Disclose Your Personal Information

1. Sharing

(1) Sharing Necessary for Contractual Obligations: In cases where it is necessary for entering into or performing a contract where you are a party, such as when you book/order hotel services, we will share the necessary information related to the transaction with the hotel or the actual provider of the goods or services according to your choice. This is to fulfill your booking/order needs and ensure the completion of the subsequent after-sales service.

(2) Sharing with Our Affiliates: To ensure the smooth completion of the services provided to you, we may share necessary personal information with our affiliates. Our affiliates will implement protection measures that are not less than those outlined in this statement and of equal stringency. We will only share necessary personal information, and it will be bound by the purposes disclosed in this statement. If we share your sensitive personal information or if our affiliates change the purposes of using and processing personal information, we will seek your authorization and consent again.

(3) Sharing with Our Partners: For the purposes described in this statement, some of our services are provided by partners or in collaboration with partners, such as electronic contract online signing services. We may share your personal information with partners to ensure the smooth completion of the services. However, we will only share your personal information for legitimate, lawful, necessary, specific, and clear purposes, and only share the information necessary for providing the services.

(4) Sharing with Explicit Consent: We will share your personal information with other parties after obtaining your explicit consent.

(5) In certain specific business scenarios, we may use capable third-party SDK (Software Development Kit) to provide services to you. These services are provided by our business partners, and you may be redirected or linked to websites or apps served by such third parties. You understand and agree that in such cases, these third parties will be independently responsible for your personal information according to their personal information protection policies. You should review their policies to determine if they meet your needs.

• Alipay SDK

  Purpose: To help users use Alipay within the app

  Data Type: Device identification information

  Privacy Policy Link: https://docs.open.alipay.com/54

• WeChat Open Platform SDK

  Purpose: To integrate with the WeChat Open Platform SDK for WeChat sharing and payment

  Data Type: Device identification information

  Privacy Policy Link:

  https://posts.tenpay.com/posts/18ed0968618e3db204d4931651708953.html

• Xiaomi PUSH

  Purpose: To push messages

  Data Type: Device identification information

  Privacy Policy Link:

  https://dev.mi.com/distribute/doc/details?pId=1534

• Huawei PUSH

  Purpose: To push messages

  Data Type: Device identification information

  Privacy Policy Link:

  https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/sdk-data-security-0000001050042177

• JPush

  Purpose: To push messages

  Data Type: Device identification information

  Privacy Policy Link: https://www.jiguang.cn/license/privacy

• Firebase – Crashlytics

  Purpose: To monitor client crashes and page exceptions

  Data Type: Device identification information, user behavior data

  Privacy Policy Link: https://firebase.google.com/support/privacy

• Geetest Validation SDK

  Purpose: To provide seamless local authentication, quick account login, and cheating behavior recognition

  Data Type: User phone number, device model, device manufacturer, phone serial number, network type and WIFI signal strength, application name/application version number, package name, package signature, phone operating system, screen size, screen resolution, carrier type, IP address, local storage permissions, sensor information

  Privacy Policy Link: https://www.geetest.com/en/Privacy

2. How We Transfer Your Information

We will not transfer your personal information to any company, organization, or individual unless:

(1) Obtain your explicit consent;

(2) According to applicable laws and regulations, it is necessary to provide it to relevant administrative or judicial authorities;

(3) When it comes to mergers, acquisitions, or bankruptcy liquidation, if there is a transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy and inform you of the recipient's name and contact information. Otherwise, we will request the company or organization to seek your authorization again.

3. How We Disclose Your Personal Information

(1) We may publicly disclose your personal information with your explicit consent or based on your voluntary choice;

The general personal information you post on the STEY platform may be disclosed to the public based on your active choices, such as:

•Part of the content on your public profile page (such as your name, city you come from, your profile photo, etc.).

•You post content on public social media or use similar functions on the STEY platform, and the relevant content is open to the public.

(2) If we determine that you have violated laws and regulations or seriously violated STEY related agreement rules, or in order to protect the personal and property safety of us and our affiliated company users or the public from infringement, we may disclose your personal information including relevant violations and measures we have taken against you, in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, or STEY related agreement rules,

4. Exceptions to Obtaining Prior Authorization and Consent for Sharing, Transferring, or Disclosing Personal Information

(1) We can collect, transfer and disclose your personal information without seeking your prior authorization in the following situations:

a) Necessary for fulfilling statutory duties or obligations;

b) Related to national security and defense security;

c) Related to public safety, public health, and significant public interests;

d) Related to criminal investigation, prosecution, trial, and execution of judgment;

e) For the purpose of safeguarding the significant legal rights and interests of personal information subjects or other individuals, such as life and property but it is difficult to obtain their consent;

f) Personal information is disclosed by the personal information subject to the public on their own;

g) Personal information is collected from legal public disclosures, such as news reports and government information disclosures;

h) Necessary for maintaining the security and stable operation of the products and/or services provided, such as discovering and handling faults in the products and/or services.

(2) For industry and market analysis, audience statistics classification, marketing and advertising, and other business purposes, we also share, analyze, and summarize information (we will depersonalize users’ information, and the information will not point to a specific user) and non-personally identifiable information. According to legal regulations, sharing and transferring anonymized personal information by which the data recipient cannot recover and re-identify the subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require separate notification to you and your consent.

IV. Storage of Personal Information

1. Storage Period

(1) We will only retain your personal information for as long as necessary to achieve the purposes stated in this policy, unless there are legal obligations for mandatory retention. For example, the E-Commerce Law of the People's Republic of China requires that information related to goods, services and transaction information be retained for no less than three years from the completion of the transaction; the Civil Code of the People's Republic of China stipulates that the statute of limitations for civil rights protection claims in court is three years; local public security authorities also require us to retain hotel check-in records for a long time for inspection.

(2) We determine the storage period of personal information primarily based on the following criteria, taking the longer one as the standard:

a) Completing transactions related to you and maintaining corresponding transaction and business records to respond to your possible inquiries or complaints;

b) Ensuring the security and quality of the services we provide to you;

c) Whether you consent to a longer retention period;

d) Whether there are other special agreements or legal provisions regarding the retention period.

(3) Once your personal information exceeds the retention period, we will delete or anonymize it in accordance with applicable legal requirements.

2. Storage Location

(1) Personal information collected and generated during our operations within the People's Republic of China will be stored within the country. We may provide your personal information to overseas entities under the following circumstances, after fulfilling legal obligations:

a) There are explicit provisions in applicable laws;

b) We obtain your separate consent;

c) It is necessary for the establishment and performance of cross-border transactions and other types of contracts in which you are a party.

We will execute this in accordance with the processes and conditions stipulated by laws, regulations, and regulatory authorities, and require overseas recipients to keep your personal information confidential and to protect its security in accordance with this policy.

(2) Accessing the STEY platform from outside Chinese mainland

If you access the STEY platform from outside Chinese mainland, please note that your information may be transferred to, stored in, and processed in mainland. Data protection laws and other laws in mainland may differ from those in your country/region, but please trust that we will take measures to protect your information. By choosing to use our products and/or services, you acknowledge and agree that your information may be transferred to our platform and shared with third parties as described in this privacy policy.

3. Ceasing Operations

If we cease to operate our platform products or services, we will promptly stop the collection of your personal information and inform you of the cessation of operations individually or through announcements. We will delete or anonymize the personal information we hold.

4. Storage Security

(1) We employ various security technologies and programs to prevent the loss, misuse, unauthorized access, or disclosure of information. Our professional security team will enhance the security of personal information (including protection and encrypted storage of sensitive information, and access control).

(2) Despite the aforementioned security measures, please understand that due to technical limitations and potential malicious means, we cannot guarantee absolute security of your information in the internet environment. We will provide reasonable security measures to protect your information and make every effort to ensure the security of any information you send to us, so that your information is not leaked, damaged, or lost.

(3) Please take good care of the devices you use to log in to the STEY platform as well as your account name and password. Do not allow others to use your device to log in or tell your password to others; when making transactions on the STEY platform, please protect your personal information and only provide it to others when necessary. Use complex passwords to help us ensure the security of your account. If you discover that your personal information has been leaked, especially your account name and password, please contact us immediately so that we can take appropriate measures.

5. Handling Information Security Incidents

If our physical, technical, or management protection facilities are damaged, leading to unauthorized access, public disclosure, falsification, or destruction of information, and damage to your legal rights, we will promptly activate our emergency response plan and take reasonable and necessary measures to minimize the impact on you. After the unfortunate incident of personal information security, we will notify you in accordance with legal requirements: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and mitigate risks, and remedial measures for you. We will inform you of the incident-related situation through email, letters, phone calls, push notifications, etc. If it is difficult to inform individuals one by one, we will publish an announcement in a reasonable and effective manner. At the same time, we will report the handling of personal information security incidents to regulatory authorities as required.

V. Your Rights to Manage Personal Information

1. Query, Copy and Modify Personal Information

(1) You can query, copy, modify, and delete your personal membership information through the following step:

“Me” – “Personal Information”

(2) You can query, copy, modify, and delete information you have published, such as Events/shares, through the following steps:

“Me” – “Events” – Three dots on the detail page - Delete

“Me” – “My Buzz” - Three dots on the detail page - Delete

(3) You can query your booking, invoices, and wallet information through the following steps:

“Me” – “booking”, “Me” – “invoices”, “Me” – “Wallet”

(4) You can contact us through the information provided in Article 8 of this policy to query your sensitive personal information or other information. After verifying your identity, we will provide it to you.

2. Delete Information

(1) You can delete some of your personal information through the step specified in the first section above mentioned, “query, copy, modify personal information”.

(2) You can delete all chat history stored on the Stey platform that was generated by the instant messaging through the following step:

Chat Interface - Three dots in the top right corner -“Delete”

(3) In the following circumstances, you can request us to delete your personal information:

a) If our handling of personal information violates laws and regulations;

b) If our handling of personal information violates the agreements with you;

c) If we collect or use your personal information without your explicit consent;

d) If you no longer use our products/services or you have canceled your account;

e) If we permanently cease to provide products or services to you.

After you delete the relevant information on your own or with our assistance, due to legal requirements or technical security, we may not be able to immediately delete the information from backup systems. We will securely store your personal information and isolate it from other information until the backup is updated to delete or the information can be anonymized.

3. Change the Scope of Consent or Withdraw Authorization

(1) You can change the scope of your consent or withdraw your consent to continue collecting personal information by deleting your personal information, turning off device functions, etc. You can also withdraw all consent to collect your personal information by cancelling your account.

(2) You can withdraw your authorization for us to transfer or share your personal information with third-party partners, Hangzhou Tiangu Information Technology Co., Ltd. (eSign), through the following step:

STEY Hotel and Long-Stay Apartment WeChat Mini Program – “Me” – “Personal Information Management” – “Electronic Contract Authorization” – “Withdraw”

(3) You can withdraw your authorization for us to collect and store your instant messaging information through the following step:

“Me” – “Settings” – “Privacy” – “Instant Messaging”

Each business function requires some basic personal information to be completed. When you withdraw your consent, we will not be able to continue providing the corresponding service. Additionally, due to the unique nature of functions of some products and relevant laws and regulations, if the service you are using has not ended (e.g., if the service process has not ended or there are outstanding payments), you may not be able to withdraw your consent until the service ends. For certain types of personal information, such as information necessary to achieve the basic functions of the STEY platform or information required by laws and regulations, we may not be able to respond to your request to change the scope of authorization.

For the data processing activities where we continuously use your personal information, we will cease processing the corresponding information once you withdraw your consent. However, the decision to withdraw consent will not affect personal information processing that was based on your authorization prior to the withdrawal.

4. Cancel an Account

You can apply for account cancellation by contacting us using the contact information provided in Article 8 of this policy. Please note that the account cancellation process is irreversible. After you cancel your account, we will stop providing products/services to you, all information related to the account will be cleared, and we will no longer collect, use, or share personal information related to that account. However, we will still need to retain previous information in accordance with regulatory requirements, and authorities have the right to access this information within the retention period. After the retention period expires, we will delete or anonymize your personal information in accordance with applicable laws. For rules and procedures related to account cancellation, please refer to the attachment “STEY Account Cancellation Agreement” of this policy.

5. Obtain Personal Information Copy

You can obtain a copy of your personal information under the law. You can contact us using the contact information provided in Article 8 of this policy to request a copy of your personal information (including basic information and identity information) from our services, after verifying your identity, except as otherwise provided by laws and regulations or this policy.

6. Response

For above requests from you or potential guardians, close relatives, and other authorized parties, and personal information rights as stipulated by laws and regulations, you can contact us through the method in Article 8 of this policy, and we will respond within fifteen working days. To ensure safety, you may need to provide a written request or prove your identity in other ways. We will respond within fifteen working days after receiving your feedback and verifying your identity. For your reasonable requests, we generally do not charge any fees, but for requests that are repeated multiple times or exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may refuse requests that are unnecessarily repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very unrealistic. In the following situations, as required by laws and regulations, we will not be able to respond to your request:

(1) Related to fulfilling obligations under national laws and regulations;

(2) Directly related to national security and defense security;

(3) Directly related to public safety, public health, and significant public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgment;

(5) Your subjective malice or abuse of power suggested by sufficient evidence;

(6) For the purpose of safeguarding the significant legal rights and interests of personal information subjects or other individuals, such as life and property but it is difficult to obtain their consent;

(7) Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests;

(8) Involving trade secrets.

VI. Protection of Minors

1. Our products and services are primarily aimed at adults. We value the protection of minors' personal information, and minors should not create their own user accounts or use our services without the consent of their parents or other guardians.

2. If you are a minor, please do not register for our accounts or use our services. If you have registered for our accounts, used our services, or provided us with information without the consent of your guardian, please stop using our services immediately and notify us so that we can take appropriate measures.

3. If you are a parent or guardian of a minor and have any questions regarding the processing of the information of the minor you are supervising, please contact us using the contact information provided in Article 8 of this privacy policy. If it is confirmed that a minor has registered and used our products/services without obtaining a guardian’s consent, we will promptly delete the relevant minor's personal information after verification.

VII. Updates to the Privacy Policy

Please understand that we may revise this privacy policy as necessary. We will indicate the date of the recent update to this privacy policy, and the updates will take effect upon publication. We will not reduce the rights you are entitled to under this statement without your explicit consent. For significant changes, we will also provide more prominent notifications (such as pop-ups to inform you of the updates). Please visit this privacy policy frequently to read the latest version. In the aforementioned circumstances, if you continue to use our services, it indicates your acceptance of the revised privacy policy and that you are bound by it. If you do not agree with the amended privacy policy, you may not be able to use our services normally.

VIII. How to Contact Us

If you have any questions, comments, or suggestions regarding this privacy policy and personal information protection, please send an email to service@stey.com to contact us. Generally, we will respond within 15 working days.

Attachment: STEY Account Cancellation Agreement

Before you confirm the cancellation of your STEY membership account, please read, understand, and agree to the following terms. During your reading, if you disagree with any part of this STEY Account Cancellation Agreement or cannot accurately understand any term, please immediately stop the account cancellation and do not proceed with the operations. By providing information, reading, and agreeing to this STEY Account Cancellation Agreement and related terms and conditions, and completing the cancellation process, you acknowledge that you have thoroughly read, understood, and accepted the whole content of this STEY Account Cancellation Agreement.

1. The account you are applying to cancel must be the account registered according to our agreement and provided to you personally.

2. You must ensure that you have the right to decide on the cancellation of the account and that it does not infringe on any third party’s legal rights. You are responsible for any complaints or disputes arising from this and will indemnify us.

3. When applying for account cancellation, you must first check and ensure that your account meets the following conditions:

(1) The account is legally owned and used by you;

(2) There are no outstanding orders or services (pre-sale vouchers, hotel bookings, etc.) in the account;

(3) The account has no remaining balance or any outstanding payments;

(4) There are no ongoing complaints, reports, disputes, penalties, or investigations by national authorities associated with the account;

(5) The account is currently valid and in normal use, not in a frozen or suspended state, with no records of account restrictions;

(6) Any other conditions published by us.

We need to specifically state that even if we determine that your account meet the cancellation conditions, it is a formal review based on your commitment (i.e., your assurance that the account meets the above cancellation conditions). You remain responsible for ensuring the account meets these conditions, and we do not bear corresponding legal responsibilities.

4. We will cancel your account and delete or anonymize the personal information associated with it within 15 working days after receiving your cancellation request. You understand and acknowledge that related transaction records must be kept by STEY for 3 years or longer according to relevant laws. Additionally, you understand and agree that we need some time to sort and process the personal information under the account to protect your legal rights to the greatest extent, before deletion or anonymization. Therefore, there may be a delay in deleting or anonymizing the personal information under the account.

5. Once the account is canceled, it cannot be recovered. Please back up all information and data related to the account before proceeding. Please retain transaction vouchers, receipts, and other documents about orders and services; otherwise, you may incur additional fees of account and order query, or may not be able to enjoy after-sales services.

6. During the period when you apply for account cancellation, if your account involves disputes, including but not limited to complaints, reports, litigation, arbitration, or investigations by national authorities, we have the right to terminate the cancellation process or freeze your cancellation request and suspend the provision of cancellation services without needing your further consent.

7. To ensure the successful completion of the cancellation, during the agreed processing period, please do not log in to STEY with the account, and if you log in to or use it, it will be considered as a withdrawal of your cancellation request.

8. Your action of canceling the STEY account will result in the termination of our services to you and will cause various inconveniences to your after-sales rights. Upon successful cancellation, we will delete or anonymize your personal information. Meanwhile, successful cancellation may result in the following outcomes:

(1) You will be unable to log in to or use your account;

(2) Personal data and historical information (account information, order records, etc.) in your account will be irretrievable;

(3) Any rights in your account (membership benefits, points, coupons, etc.) will be deemed as voluntarily forfeited and cannot be used.

You understand and agree them, and STEY cannot assist in restoring the aforementioned services.

9. Once the account is canceled, the user agreement related to STEY and other documents about rights and obligations signed by you will be terminated (except those that have been agreed to remain in effect). However, the termination of the above agreement does not relieve or exempt you from responsibilities you (may) need to bear during the agreement period according to relevant laws, regulations, agreements, rules, etc., including but not limited to potential liabilities for breach of contract or damages, and performance obligations.

10. This agreement is a part of the Terms & Conditions (“main agreement”). Matters not covered in this agreement shall be governed by the main agreement. In case of any inconsistency between this agreement and the main agreement, this agreement shall prevail.

11. Contact us: If you encounter any problems or have any doubts during the account cancellation process, please contact our customer service for assistance.