LOHKAH HOTEL GROUP PRIVAVY POLICY

Last Updated: December 31, 2025

INTRODUCTION

Lohkah Hotel Group (hereinafter referred to as "Lohkah", "we", "us", "our") respects your privacy and is committed to protecting the privacy, confidentiality and security of the personal data you provide to us or that we collect about you when you use our official website lohkah.com (hereinafter referred to as the "Site"). We are fully aware of our responsibility to properly protect your personal data, ensure its security and comply with applicable privacy and data protection laws. For the purposes of this Statement, "personal data" shall have the meaning ascribed to it by applicable privacy or data protection laws (including but not limited to the Personal Information Protection Law of the People's Republic of China).

This Statement explains our practices regarding the processing and protection of your personal data, as well as the rights you hold as a data subject and the methods for exercising such rights. This Statement embodies our commitment to protecting your personal data and serves as guidelines to be followed by all hotels, resorts and properties managed and/or operated by Lohkah, its affiliates and subsidiaries. Please carefully read and fully understand all contents of this Statement before providing any personal data to us.

When you subscribe to e-Newsletters through the Site, establish other communications with us, or in circumstances required by applicable law, we will seek your consent to this Statement. To the extent permitted by applicable law, your continued use of the Site shall constitute your acknowledgment and acceptance of the contents of this Statement.

TYPES OF PERSONAL DATA WE COLLECT

1. Information You Voluntarily Provide

When you choose to subscribe to services such as e-Newsletters, we will collect information including your title, name (given name and family name), email address and country/region, all of which are personal data you directly provide to us.

2. Information Automatically Collected Through Cookies When You Use the Site

When you access the Site using devices such as computers and mobile phones, we may automatically collect certain information through Cookies technology, including your preferred language, region, IP address, device MAC address, browser type, duration of stay on the Site, browsing history, and referring URL. Such information will be used to send you personalized advertisements for Lohkah and third-party products via email, on this Site or other websites, analyze your interaction with the Site, and maintain your preference settings. For detailed information about Cookies and how to disable them, please refer to the section "Explanation of Cookies and Similar Technologies" in this Statement.

3. Provision of Third-Party Information

If you provide personal data of third parties to us, you confirm that you have obtained their consent or have a legitimate legal basis for providing such personal data to us. We recommend that you show this Privacy Protection Statement to them.

RULES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

To the extent permitted by applicable law, we may collect, use and disclose your personal data for the following purposes:

• Sending you our e-Newsletters and providing you with our latest news and promotional information;

• Monitoring and analyzing the use of the Site to operate, evaluate, protect and improve the Site and our services, and understand your preferences;

• Providing you with products, services, promotional activities and relevant information that may be of interest to you;

• For any other purposes by us or our third-party service providers with your consent, in accordance with the requirements of applicable law.

In addition to the above circumstances that require your consent, we may also legally collect, use and disclose your personal data in the following situations:

1. It is necessary for the conclusion or performance of a contract to which you are a party;

2. It is necessary for the performance of our statutory duties or obligations;

3. It is necessary to respond to public health emergencies or to protect the life, health and property safety of you or other natural persons in emergency situations;

4. Processing your self-disclosed or otherwise legally disclosed personal data within a reasonable scope in accordance with the requirements of applicable law;

5. Other circumstances prescribed by laws and administrative regulations.

EXPLANATION OF COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files containing a small amount of information that are downloaded and stored on your Internet-connected devices (such as computers, mobile phones, and tablets) — similar to a memory for a web page. The following types of first-party Cookies and third-party Cookies are used on the Site:

• Necessary Cookies: Necessary Cookies are essential for you to navigate the Site. These Cookies support the security and basic functions of the Site and are indispensable for the proper operation of the Site. Therefore, if you disable these Cookies, we may not be able to ensure your usage experience and security during your visit to the Site.

• Functional Cookies: Functional Cookies are used to provide you with a better user experience. These Cookies can also identify whether a Site user has subscribed to the e-Newsletters of our related services or if the user is visiting the Site for the first time.

• Performance Cookies: Performance Cookies help us understand the behavior of visitors and their use of the Site, enabling us to continuously improve the Site and provide you with the best possible user experience. These Cookies are also used to help us understand user interests and measure the effectiveness of our advertisements. The following Performance Cookies are used on the Site:

• _pk_id.* and _pk_ses.* stored by us for 13 months and 1 hour respectively — We use these two Cookies to conduct first-party visitor traffic monitoring.

• Advertising Cookies: Advertising Cookies will record your general preferences when you visit the Site. Where possible, we strive to provide you with advertisements for hotels, resorts, and other products and services that may be of interest to you on other online platforms. These Cookies are also used to limit the number of times you see an advertisement and help measure the effectiveness of advertisements.

We will store Cookies on your computer or device to remember your preferences for your next visit. You can change your browser settings to receive a prompt before certain Cookies are stored. You can also adjust your settings to allow your browser to refuse most of our Cookies or only certain third-party Cookies. If you wish to withdraw your consent at any time, you can delete our Cookies through your browser settings. You should perform this operation on each browser you use. Please note that if your browser does not accept Cookies, we may not be able to provide certain services normally. However, you can allow Cookies from specific websites by setting them as "trusted sites" in your browser.

EXTERNAL DISCLOSURE OF PERSONAL DATA

To improve the efficiency of information processing, we may entrust our affiliates and third-party service providers (such as IT service providers and marketing service providers) to process your personal data on our behalf. We will sign strict confidentiality agreements with these third parties and require them to process personal data in accordance with our requirements, this Statement, and the confidentiality and security measures stipulated by applicable law.

Subject to the provisions of applicable law, for the aforementioned purposes (where applicable), we may share your personal data with the following parties:

• Disclose to any law enforcement agency, court, government or regulatory authority (regardless of jurisdiction), or provide information when we believe such disclosure complies with any applicable law or regulation, or is required by a court order or legal process;

• Disclose to any business partner, investor, assignee or transferee (actual or potential) for the negotiation of transactions related to business assets or to facilitate any business asset transaction (including any merger, sale of company assets, financing, or acquisition of all or part of the business by another company, or change of hotel management);

• Disclose to any other party with your consent, instruction or authorization;

• Disclose in other ways permitted or required by applicable laws and regulations.

We may also disclose aggregated or anonymized data that cannot identify individual persons to third parties (including commercial and strategic partners).

OVERSEAS TRANSFER OF PERSONAL DATA

If you are located in Mainland China, when you subscribe to e-Newsletters, we will transfer your personal data to Xiamen, Fujian. The specific details are as follows: the purpose of the transfer in this scenario is to provide e-Newsletter services; the transferred information includes your title, name, email address and region; the purpose of the recipient's processing is to provide e-Newsletter services; and the processing methods include collection, use, storage, transfer and entrusted processing.

Except for the above scenario, if your personal data involves overseas transfer, we will only conduct such transfer after confirming that the destination has adequate level of personal data protection or appropriate safeguard measures have been taken.

DIRECT MARKETING COMMUNICATIONS

With your consent, we will send you marketing information about Lohkah hotels, products, services and events via email (based on your title, name, email address, region and other information).

You may opt out of receiving marketing information at any time: by following the unsubscribe instructions contained in the marketing emails, or by contacting our customer service channels. After unsubscribing, we may still send you non-marketing communications, unless prohibited by applicable laws.

RETENTION PERIOD OF PERSONAL DATA

We will only retain your personal data for the period necessary to achieve the purpose of collection or as required by applicable law. Upon expiration of the retention period, to the extent required or permitted by applicable law, we will take reasonable and secure measures to delete, destroy, anonymize or redact your personal data.

COMMITMENT TO DATA SECURITY

We have implemented appropriate technical and organizational measures to prevent unauthorized or accidental access, tampering, deletion, leakage or misuse of your personal data. These measures are subject to regular review and monitoring. However, please note and understand that we cannot guarantee absolute security of the network. If you find that your personal data has been leaked, please contact us immediately using the contact information provided in this Statement so that we can take corresponding measures.

In the event of any accident, force majeure or other circumstances leading to the leakage of your personal data, we will make every effort to control the situation and promptly inform you of the cause of the leakage, the security measures we have taken and that you can take, as well as other relevant information. In the event of a personal data security incident, we will report to the competent authorities in accordance with the requirements of relevant laws and regulations, promptly investigate the issue and take emergency response measures.

PROTECTION OF MINORS' PERSONAL DATA

Except as required by applicable law, we will not intentionally collect personal data from minors. If you are a minor under 18 years of age in Mainland China, please do not use this Site or provide us with your personal data.

If you are the parent or guardian of a minor and have questions about how we process the minor's personal data, you may contact us using the contact information provided in this Statement.

THIRD-PARTY LINK NOTICE

This Site may contain links to websites, applications, content or services operated by third parties. These third-party platforms have their own independent privacy policies, and we are not responsible for their policies or personal data collection behaviors. Before providing personal information to these third-party platforms, please review their privacy policies.

YOUR RIGHTS AND CONTACT INFORMATION

Pursuant to applicable law, you have the right to access, correct, delete your personal data, request restriction or transfer of the use of your personal data, or file a complaint with the competent authority; you may also withdraw your authorization for receiving marketing information and processing personal data based on consent at any time, or request deletion of your personal data (please note that withdrawing consent or requesting deletion of data may result in the inability to continue providing services or termination of relevant agreements).

If you wish to exercise any of the above rights, please contact us through the following channels:
Lohkah Hotel Group
Address: No. 277 Penang Road, Huli District, Xiamen City, Fujian Province, China
Email: info@lohkah.com

We will respond to your request within the time limit stipulated by law. However, we may not be able to satisfy your request in the following circumstances:

1. Conflicts with our performance of legal obligations;

2. Involves national security and national defense security;

3. Involves public security, public health and major public interests;

4. Involves criminal investigation, prosecution, trial and execution;

5. There is sufficient evidence to prove that you have malicious requests or abuse of rights;

6. It is necessary to protect your or other individuals' major legitimate rights and interests (such as life and property) but it is difficult to obtain your authorization;

7. Responding to your request to exercise rights will seriously harm the legitimate rights and interests of you or other individuals or organizations;

8. The requested data involves trade secrets.
   
   UPDATE OF THE STATEMENT
   
   

We may update this Privacy Protection Statement from time to time. The updated content will be published on this Site, and we recommend you review the latest version when visiting the Site or interacting with us. The updated Statement will indicate the effective date and take effect immediately upon publication; if the updated content has a significant impact on your rights and obligations regarding our handling of your personal data, it will only apply to personal data after the Statement takes effect (when required by law, we will separately obtain your consent for major updates to the Statement).

OTHER EXPLANATIONS

This Statement is formulated in English and may be provided in other language translations; in case of any inconsistency between different language versions, the English version shall prevail.