SEIBU PRINCE CLUB emi Basic Policy on the Protection of Personal Information
As outlined in their Group Vision, Seibu Holdings Inc. (hereinafter referred to as the “Company”) and the companies of the Seibu Group (refers to the Company as well as its subsidiaries and affiliates; hereinafter referred to as “Group Companies” with the Company and Group Companies to be referred to collectively as the “Group”) have espoused contributing to the development of the community and greater society and to environmental preservation and providing safe, secure and comfortable services as the philosophy behind their business activities. The Company recognizes that in order to realize that philosophy, it is essential that it gain the trust of its customers, shareholders, employees and the community as a member of society, and is currently endeavoring to establish a compliance system as its highest-priority management issue. Moreover, the Company recognizes that the proper handling of personal information constitutes a significant issue from the standpoint of compliance.
The Company will set forth a basic policy below on the protection of personal information of membership applicants, persons registered for campaigns and questionnaires and members (persons who lost member eligibility included; hereinafter referred to collectively as “Members, etc.”) handled in the SEIBU PRINCE CLUB emi Point Program (hereinafter referred to as the “Program”) and campaigns, questionnaires, etc. carried out in association with the Program (hereinafter referred to collectively as the "Program, etc.") or otherwise handled in association with the Program, etc., and will implement and continuously improve the protection of personal information
Seibu Prince Club Desk shall be the department that will be responsible for protecting personal information for the Program.
Article 1. Types of personal information
- Personal information acquired from Members, etc. and held by the Company (hereinafter referred to as “Personal Information”) shall be as follows.
- Name, date of birth, gender, nationality, address, and telephone number provided by Members on the specified membership application website, and any other information provided by Members;
- E-mail address and other information provided by Members through the member site and the campaign site for web registration or participation in questionnaire surveys; and
- Usage history related to Transactions.
- Contact details (email address, telephone memos, letter, questionnaire response content, etc.)
- Information automatically collected by the SEIBU PRINCE CLUB emi Website (“Website”) (cookies, IP addresses, browser type, access date and time, etc.)
- Information on Members, etc. that is gathered/held by the Company in transactions with/usage of the Company and its various Group companies in Japan as well as SEIBU PRINCE CLUB emi member stores (hereinafter referred to as “Member Stores, etc.”) in relation to the Program, etc.
- The Company shall acquire personal information directly from members via telephone, in writing (including on magnetic storage media), via passports, or other means.
Article 2. Handling of Personal Information
- The Company will use Personal Information for the below purposes only after it has taken necessary measures to protect that information.
- To provide services incidental to point allocation and the Membership Card by the Member Stores.
- For various announcements with respect to information regarding business information, product information, etc. of the Member Stores.
- For product development, market research, etc. for the products and services offered by the Member Stores.
- For communications from the Member Stores to Members that are necessary for Transactions and for confirming transaction details.
- For responding to inquiries, opinions, and requests from Members to the Member Stores.
- For exercising rights, or fulfilling obligations, under a contract or the like.
- For communications and operations management of transactions.
- For cancelling transactions or follow-up management after cancelling transactions.
- For communications with Members, etc. in emergencies.
- For facilitating the performance of transactions or contracts.
- Even if the Company or a Member Store uses Personal Information within the scope agreed to by a Member, the Company or Member Store shall, upon request of the Member, stop using such information to the extent that it will not disturb its business operations. Membership applications, etc. that were submitted at the time of joining the Program will be disposed of using appropriate methods once the necessary tasks have been completed. Please note that for that reason, membership applications, etc. that were submitted will not be returned whatsoever.
Article 3. Disclosure and Provision of Personal Information to Third Parties
- Provided that there are no cases, etc. dictated by the SEIBU PRINCE CLUB emi Membership Terms and Conditions, the SEIBU PRINCE CLUB emi Terms of Consent on the Handling of Personal Information (Special Provisions) or laws, ordinances, etc. or other special reasons, the Company will neither disclose nor provide Personal Information on Members, etc. to third parties without the agreement of Members, etc.
- The Company may consign handling operations for Personal Information to third parties within the scope of the notified or disclosed purpose of use. In such cases, the Company will oblige the consignee under contract to properly manage Personal Information in accordance with laws, ordinances, etc. and will endeavor to appropriately supervise the management of the protection of Personal Information.
Article 4. Shared Use of Personal Information
The Company will conduct the shared use of Personal Information on Members, etc. with Member Stores, etc. as shown below only after it has taken necessary measures to protect that information.
- Items of Personal Information whose use will be shared
- Name, date of birth, gender, address and telephone number stated or entered by Members, etc. on or into the designated membership application form or other forms, etc. and other items reported by Members, etc.
- Email addresses and other information reported by Members, etc. through online registration for the members’ site, campaign site, etc. as well as through questionnaires, usage, etc.
- Usage history regarding Transactions
- Scope of shared users
Member Stores, etc.
- Purpose of use of shared users
Purpose prescribed in Article 2.1
- Managing supervisor of shared use
Name: Seibu Holdings Inc.
Address: 1-16-15 Minamiikebukuro, Toshima-ku, Tokyo
Representative: Takashi Goto, President and Chief Executive Officer
Article 5. Addition or change to the purpose of use
The Company will use Personal Information within the scope of the purposes for which they have notified Members or published. The Company will announce the Members in any event to use Personal Information for a purpose beyond the stated scope.
Article 6. Consent to provision of personal information
Members consent to the handling of personal information by the Company by declaring their intent to consent to the SEIBU PRINCE CLUB emi Membership Terms and Conditions, Terms of Consent on the Handling of Personal Information (Special Provisions), and in principle the Company handles Member personal information in accordance with consent from Members. However, Members can revoke this consent at any time. In addition, Members under 16 years of age must obtain the consent of their guardian in order to use participate in the Program. In addition, the personal information provided by Members is required for the Company to provide the Program and related services to the Members, so there may be cases the Members who do not provide said personal information cannot make use of the Program and services.
Article 7. Legal basis for use of personal information
In principle, the legal basis for use of personal information by the Company is the consent of Members to the use of said information. In cases of use of personal information without Member consent, the legal basis for said usage shall be the necessity of use for execution of Member contracts, the necessity of use for execution of procedures in accordance with Member requests before the conclusion of a contract, the necessity of use for fair profit by the Company or third parties, or the necessity of use in order for the Company to fulfill legal obligations. Use for fair profit by the Company or third parties applies to use for increasing operating profit, etc. through marketing and service improvements, and improving the convenience and security of this Website.
Article 8. Personal information retention period
Company retention of personal information shall be limited to the period of valid membership, which is a period lasting until December 31 of the year that includes the day on which five years will have passed since the last use of the Program (last date of Point allocation). In addition, in the event a Member withdraws from membership during the period of valid membership, personal information shall be retained until December 31 of the year that includes the day on which 1 year will have passed since the member withdrew. In addition, the Company shall erase or anonymize through safe measures any personal information within a reasonable period of time after the expiration of the personal information retention period.
Article 9. Cookie usage
The Company may use the information collected using cookies from Members who browse the Website as Member information by combining it with information that identifies individual Members.
Article 10. Use of Google Analytics
Article 11. Member Rights
Members possess the following legal and other rights in regard to the Company. Members may exercise these rights by contacting Desk's personal information contact point. Upon exercise of said rights, the Company shall conscientiously work to comply with said exercise of rights after verifying membership as long as no legal or other extraordinary exemptions apply.
- Right to access personal information
A right to verify if member personal information is being used, and if being used to access said personal information and incidental information
- Right to correct personal information
A right to correct any incorrect Member personal information
- Right to erase personal information
A right to erase Member personal information under a fixed set of conditions
- Right to restrict use of personal information
A right to restrict the use of Member personal information under a fixed set of conditions
- Right to object to the use of personal information
A right to object to the use of Member personal information by the Company or any third parties on the basis of seeking fair profit
- Right to data portability
A right to have personal information provided by the Member to the Company structured to be used in a standard machine-readable format, and to transfer said personal information without any impedance by the Company.
Article 12. Establishment of a management system
- Formulation of Personal Information Protection Guidelines
- The Company has formulated these guidelines (Personal Information Protection Guidelines) for “compliance with related laws, ordinances, guidelines, etc.” and “counters for questions and complaints processing” in order to ensure the proper handling of Personal Information.
- Establishment of rules pertaining to handling of Personal Information
- The Company has established a supervisory system by formulating internal regulations related to the handling of Personal Information for handling methods, supervisors/personnel, their duties, etc. at each stage of information, including acquisition, usage, storage, provision, deletion and disposal.
- Organizational security control measures
- In addition to establishing a supervisor post for the handling of Personal Information, the Company has clarified employees who handle Personal Information and the scope of Personal Information handled by said employees, and has established a system for reporting to/notifying said supervisor when an actual violation of the Personal Information Protection Act or the Personal Information Protection Regulations or a sign thereof has been ascertained.
- In addition to regularly implementing self-checks on the status of Personal Information handling, the Company has the internal department in charge supervise said status.
- Human security control measures
- The Company regularly trains its employees in items to bear in mind regarding the handling of Personal Information.
- The Company states items regarding the nondisclosure of Personal Information in its Working Regulations.
- Physical security control measures
- In addition to managing employee access to areas where Personal Information is handled and limiting devices, etc. that can be brought into those areas, the Company takes measures to prevent the viewing of Personnel Information by nonauthorized persons in said areas.
- In addition to taking measures to prevent the theft, misplacement, etc. of devices, electronic media, documents, etc. used to handle Personal Information, the Company takes measures to ensure that Personal Information is not easily ascertained in cases where such devices, electronic media, etc. are carried about, including when they are relocated within the same office.
- Technical security control measures
- The Company implements access control and limits the scope of personnel, Personal Information databases handled, etc.
- The Company has introduced systems to safeguard information systems used to handle Personal Information from illegal access from external parties or from illegal software.
Article 13. Filing of objections with regulatory authorities
In accordance with the law and other regulations, members shall have the right to file objectives with the national government, regional governments, international organizations, or other regulatory authorities regarding the handling of personal information by the Company.
Article 14. Profiling and other automated decision-making
The Company does not carry out any decision-making based solely on profiling or other automated handling of personal information.
Article 15. Matters not stipulated
Any matter not stipulated in this policy shall be subject to the “Seibu Holdings Basic Policy on the Protection of Personal Information.”
Article 16. Governing law and court of jurisdiction
- The text of this policy is given in Japanese. In the event the policy is translated into languages other than Japanese, only the Japanese text shall be valid and text that has been translated into any other language will have no effect whatsoever.
- Unless otherwise provided, this policy and the use of Personal Information shall be governed by the laws of Japan.
- The Tokyo District Court shall have exclusive jurisdiction for the first instance over any dispute with respect to this policy or the use of Personal Information.
Article 17. Contact point
The following contact point will handle any inquiries about the Personal Information handled by or in the possession of the Company.
SEIBU PRINCE CLUB Desk, Contact Point for Personal Information Inquiries
- 1-11-1 Kusunokidai, Tokorozawa-shi, Saitama, 359-8510
- Phone: 03-5952-2350
- Supported Languages: Japanese, English, Chinese, Korean
- Operating Hours: 9:00 a.m. to 5:00 p.m. Japan time (excluding Saturdays, Sundays, holidays and New Year holidays)
Last Updated: April 1, 2022