Current Version: March. 9th, 2026 Version
Enforcement Time: March. 9th, 2026
INTRODUCTION
- naked (hereinafter referred to as "we", "us" or "our") fully understands the importance of personal information to you. We will protect the security of your personal information in accordance with laws and regulations. We have developed this Privacy Statement hoping you will understand the methods of collection, use, and disclosure of personal information described below.
- This Statement applies to the platform services we provide to you in the form of mini-programs and websites, as well as emails and text messages sent to you based on these platform services, and online or face-to-face communications between you and us.
- This Statement does not apply to products/services (including any third-party applications, websites, etc.) contained within or linked to from the naked platform. Such products/services are operated by third parties and are subject to the personal information protection policies or similar provisions of those third parties.
- If you submit any personal information about other individuals to us or our information sharing partners, you represent that you have obtained the appropriate authorization, and you permit us to use such information in accordance with this Privacy Statement.
Important content concerning your rights regarding personal information in the following sections is highlighted in bold and underlined for your special attention.
Collection and Use of Personal Information
naked collects your personal information through two primary methods: ① directly from you, and ② indirectly from information-sharing partners. These partners include, but are not limited to, naked brand hotels, our affiliated companies, travel agencies, third-party online hotel booking platforms, and cooperative marketing partners. We require all information-sharing partners to ensure the legality and compliance of the personal information provided.
The categories of information collected may vary depending on the specific service type and processing scenario, as detailed in the table below:
| Service Type | Specific Scenario | Information Category |
|---|---|---|
| Operation and General Business of naked | Providing room reservations, dining, and activity booking services, and sending you confirmation notices | Name, gender, mobile number, email, Cookie |
| For automatic license plate recognition at the hotel entrance and to provide complimentary parking when you drive to the hotel | License plate number | |
| Fulfilling identity verification obligations as required by law, retaining relevant information as proof of compliance | Identification documents (e.g., ID card, passport), facial recognition information, mobile number; if accompanying minors or other minors under guardianship, similar information of such minors must also be collected | |
| Providing Wi-Fi internet access | Mobile number | |
| Requesting mailing services for items purchased at the hotel boutique or left-behind items | Recipient's address, recipient's name, mobile number | |
| Voluntary participation of minors or other minors under guardianship in hotel activities with certain risks (e.g., horse riding) | Your name, mobile number, minor's name, age | |
| Providing hotel Spa services | Health information | |
| Providing special services for anniversaries or special occasions | Anniversary date, special occasion details | |
| Providing electric vehicle shuttle services within the hotel | Location Information | |
| When you communicate with customer service and need to share images or request activity materials | Images you provide and any portraits contained therein; Communication information (e.g., email, phone number) | |
| Ensuring on-site security, handling accidents, emergencies, etc., with security cameras installed in public areas (e.g., corridors, lobbies). | Images or audio/video data that may contain portraits or voices of you or minors under your guardianship | |
Monitoring and analyzing service usage, improving services, planning, and overall customer experience, collecting feedback, conducting pilot programs for potential new services, developing new services, and improving existing services. Note: If you do not consent to our processing of this personal information, we may not be able to provide you with additional or optimized features and experiences, but you can still enjoy our other products or services. | Behavior preferences, gender, age, browsing, search, and favorites history, interactions and related information in official WeChat public accounts | |
| Delivery of goods/services to you | Completing the electronic redemption of goods, services, or their offers. | Recipient information for the goods or services (e.g., name, mobile phone number, email address) |
| Membership Services | If you wish to become a member, to create a recognizable membership account for you and to facilitate the setup of your membership account avatar and nickname. | WeChat Nickname, WeChat Avatar, Mobile Number |
| If you change your avatar after membership registration. | The image you select and provide, and any portraits that may be contained therein. | |
| To provide you with more personalized membership services. Note: You may also choose not to provide this information; this will not affect your right to register as a member. | Name, Gender, Birthday, City, Number of Children | |
| Push products/services/surveys to you | To keep you informed about our product/service marketing information and improve our service quality, we may provide you with the latest benefits, points change notifications, surveys, event updates, or promotional information about products/services you may be interested in via SMS, email, or mini-program messages free of charge, as well as to provide you with more personalized and convenient marketing information Note: If you have not granted corresponding permissions, push notifications and/or personalized recommendations will not be enabled, and you will not receive our marketing information, or the information you see may not be of interest to you. | Name, gender, age, order information, behavior preferences, browsing, search, and favorites history, WeChat unionid, membership account (if applicable), phone number, email, IP address, device information, service logs, Alipay Life Account, interactions and related information in official WeChat public accounts |
Use of Equipment Permissions
For the purpose of providing the above services, we need to obtain your device permissions for the following. If you would like to change or disable such permissions, you can manage these permissions through your device's Settings.
| Required Device Permissions And The Features They Support | Personal Information Involved | Consequences Of Not Providing Such Permissions |
|---|---|---|
| Location: Help with your localization | Location information | You may not be able to use the in-hotel electric car shuttle service provided by the Mini program. |
| Camera: For you to take photos/videos | Images and/or videos taken with your device | You may not be able to upload avatar, pictures by taking photos ; not be able to upload pictures, photos, screenshots, etc. that you want to send to customer service during communicating. |
| Notifications: Provides you with notifications from the mini program. | Device ID to record your device's preference for receiving push notifications. | You may not receive notifications from the mini program. |
| AD analytics and tracking: Analyze your engagement with the ads to deliver personalized ads. | Device identifier assigned to your mobile device | You may not be able to receive personalized ads. |
| Device permissions required by third parties: If you choose to access the websites or apps of third parties, such as banks and credit card companies, through links in our mini program, those third parties may ask to connect to your device's photo library, contact list, and microphone functionality. These permissions are requested by third parties and not by our mini program. | This authorization does not cause our platform to collect other additional personal information. | You may not be able to access third party websites or applications through links in our platform. |
| Bluetooth: Provides you with Bluetooth unlocking service for smart door locks | You are unable to open the door via Bluetooth, but you can still use the room card to do so. |
Share of Your Personal Information
- Sharing according to law: We may share your personal information in accordance with laws and regulations, necessary for the resolution of litigation disputes, relevant agreements signed by you and us (including online signed electronic agreements and platform rules) or legal documents, or in accordance with the requirements of administrative, judicial and other competent authorities in accordance with the law, and necessary for the performance of other legal obligations;
- Sharing where necessary for the conclusion and performance of the contract to which you are a party: When you book/place an order for a hotel or other goods or services, we will, according to your choice, share the necessary information related to the transaction in your order with the stores, merchants or actual providers of related goods or services to meet your needs for the booked/ordered hotel or other goods or services, and enable them to complete subsequent services;
- Sharing with our affiliates: In order to ensure the successful completion of the services provided to you, we may share necessary personal information with our affiliates. Our affiliates will take protective measures no less stringent than this statement. We will only share the necessary personal information, and is bound by the purpose stated in this statement, if we share your sensitive personal information, or affiliates change the purpose of the use and processing of personal information, we will again seek your authorization and consent.
- Sharing with our partners: Some of our services will be provided by or together with our partners only for the purposes described in this statement, such as location services, post-stay value-added services. We may share your personal information with our partners to ensure the successful completion of the services we provide to you. However, we will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share personal information necessary to provide services.
- Optimize service quality and security risk control: To enhance the quality of our services, we may disclose personal and other information to third-party service providers, including companies that provide data analysis, SMS push notifications, email distribution, and other related services. To fully ensure the security of your account and transactions, enhance your safety while using the naked Home platform, protect your property from infringement, and better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, cyber attacks, and unauthorized access, we may share necessary device information, service log information, etc., with security risk control service providers for the prevention and handling of security incidents.
- Third Party SDKS: For the purposes described in this Statement, some third-party software development kits (SDKS) will be added to the naked Platform to support specific functions of the naked Platform. We will require third parties to collect and use your personal information within the scope of your authorization based on the principles of legality, legitimacy, necessity, good faith and clarity, and take necessary information protection measures, but such third parties will be independently responsible for the protection of your personal information. Its liability basis (such as the privacy statement formulated by the third party) is subject to the latest link published by the third party and the content of the linked web page.
You can see below to learn the details of the collection and use of your personal information by third party SDKS and their privacy policies:
| Third Party SDK Name | Purpose and Function of Use | Types of Personal Information Collected | Name of Third-Party Organization | Third Party Privacy Statement |
|---|---|---|---|---|
| Tencent computer system Co. Ltd. | TPNS SDK | Equipment Information Network Information Application Information Application Data | Mobile device notification push | https://privacy.qq.com/document/preview/8565a4a2d26e480187ed86b0cc81d727 |
In addition to the above, if we share your personal information with any other company, organization or individual, we will again seek your express consent or authorization.
Other Provisions
- Device information: Including device identifiers (IMEI, IDFV, Android ID, MAC, OAID, and other device-related information), application information (application crash information, notification switch status, application installation list, and other application-related information), device parameters, and system information (device type, device model, operating system, and hardware related information), device network environment information (IP address, WiFi information, base station information and other network related information). The specific information is subject to actual information collection of the product
- Service log information: including browsing record, click and view record, search record, sharing information, publishing information, IP address, browser type, telecom operator, language used, access date and time, etc.
Cookies：We collect certain data through cookies, which are stored directly on your computer or mobile device. Cookies allow us to collect browser type, duration of access to online services, history of visited pages, referral sites, language preferences, and other aggregated traffic data.
We use functional cookies for the following security purposes: to facilitate navigation, to display content more efficiently, to collect statistics, to provide you with a personalized experience when you use the online Services, and to identify your computer to assist you in using the Online Services. We also collect statistical Cookie data about the use of our online services in order to continuously improve the design and functionality, understand their use and help us resolve related issues. With advertising cookies, we can also select advertisements or offers that may be of particular interest to you and show you when you use the online services. We also use cookies to send marketing emails and to track responses to online advertising and marketing emails.
Manage your Cookie preferences: You can choose whether you agree to use cookies in the following two ways: ① Click "Tracking Preferences" to manage your tracking preferences; ② Change the Settings in your browser. However, if you refuse to accept cookies, you may not have a good experience using online services. For example, you may also not be able to receive promotional messages or other offers that we send you based on your interests and needs. If cookies are not enabled, we do not respond to the browser's "Do not Track" signal.
Retention: We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep your records for a certain period of time before we can delete them);
- Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations)
- Sensitive Data：We ask that you not send and/or disclose to us on or through the Services any Sensitive Personal Information (e.g., credit or debit card details or financial account number, with or without any code or password that would permit access to the account, information on race, religion, medical or health information or other information that could lead to discrimination or seriously harm the personal and property safety if disclosed or used without authorization). Please note our disclosures regarding the handling of sensitive personal information, which are highlighted in this Privacy Statement.
- Minor Users of the Service: In principle, our users must be at least 18 years old. If you are a minor, you should use our products/services under the guidance of a guardian to ensure your safety while using our products/services and conducting transactions. If there is evidence that a minor has registered and used our products/services without the consent of their guardian, the guardian may contact us through the methods specified in this statement. Upon verification, we will delete the relevant personal information of the minor as soon as possible.
Contact Us
Unless otherwise specified, the data controller responsible for your personal information is naked Hotel Management (Shanghai) Co., Ltd. with an address of: Room 01-03, 32F, 500 West Yan’an Road, Shanghai.
If you have any questions about this Privacy Statement, please contact us at:
E-mail: reservation@livenaked.com
Tel: 400 9200 518
