SEIBU Smile ID Basic Policy for Personal Information Protection

Seibu Holdings Inc. (hereinafter referred to as "the Company") and the companies of the Seibu Group (which means Seibu Holdings Inc. and its subsidiaries and affiliates, hereinafter referred to as "Group Companies"; hereinafter collectively referred to as "the Company and the Group Companies"), as set forth in the Group Vision, aim to contribute to the development of the local community and society, to the preservation of the environment, and to provide safe, secure, and comfortable services as the business philosophy. In order to achieve this, we recognize that it is important for us to gain the trust of our customers, shareholders, employees, and the local community as members of society, and we are currently working to build a compliance system as our most important management issue. Furthermore, we recognize that the proper handling of personal information is an important compliance issue.

We have established the following basic policy regarding the protection of personal information of applicants for ID issuance, those who have registered for campaigns and surveys, and ID holders (including those who have lost their ID eligibility, hereinafter referred to as "ID Holders") in connection with the service we provide under the name "SEIBU Smile ID" that allows users to log in using a common ID to various services and content provided by our group or its partners, as well as other services for ID holders, and campaigns and surveys conducted in connection with this program (hereinafter referred to as "Services, etc."), and we will implement and continuously improve the protection of personal information.

1.Handling of Personal Information

1. (1)We will use personal information of ID holders, etc. (hereinafter referred to as "Personal Information") collected and held in all transactions and use of the Services with our Group, including ID issuance applications and ID issuance (hereinafter referred to as "Transactions"), for the following purposes, after taking necessary protective measures.
   1. AProvision of a service that enables users to log in to various services and content provided by our Group or its business partners using a common ID (hereinafter referred to as the "Login Service").
   2. BProviding various information such as our group's sales information and product information
   3. CProduct development and market research related to the products and services handled by our group
   4. DThe Group will contact ID holders, etc., as necessary for transactions and to confirm the details of those transactions.
   5. EResponding to inquiries, opinions, and requests from ID holders, etc. within the Group
   6. FTo exercise rights and fulfill obligations based on contracts, etc.
   7. GFor communication and business management regarding transactions
   8. HFor the purpose of canceling a transaction or for post-termination management after the transaction has been cancelled
   9. ITo contact ID holders in case of emergency
   10. JTo smoothly execute transactions and contracts
   11. KTo use for the purpose of item 2 (C)
2. (2)In providing the Services, etc., the Company will receive personal information of ID holders, etc. as specified below from each Group company and use it for the purposes specified in 1(1).
   
   Items of personal information provided by group companies
   1. (A)Basic personal information
      • Name, date of birth, gender
      • Contact information such as address, telephone number, email address, SNS, etc.
      • Occupation and place of employment information
      • Information about your family (including names, addresses, dates of birth, and contact information)
      • Other personal information obtained from personal information obtained from service users, applicants, or subscribers in relation to various services and content provided by each Group company (hereinafter referred to as "Individual Services").
   2. (B)Information obtained from various contracts, reservations, applications, facility and service use, etc. for individual services, usage history information, and purchase history information
      • Information obtained from various contracts, reservations and applications (date and time, amount, details, application channel, etc. related to the contract, etc.)
      • Information obtained from the use and purchase of each facility and service (card information, point information, service usage history, product purchase history, etc.)
      • Participation information for special events, events, campaigns, etc.
   3. (C)Service usage history information and access log information for individual services
      • User ID, application used, start date and time, operation log, cookie, cache ID, access date and time, access log, and other usage history and access log information
   4. (D)Opinions regarding individual services, content and history of inquiries, information regarding transaction needs, and other information acquired incidental to the provision of individual services
      • Surveys, chats, conversation information, etc.

2.Joint Use of Personal Information

The Company will jointly use personal information of ID holders, etc. with group companies as follows, after taking necessary protective measures.

1. AItems of personal information to be jointly used
   1. (A)Basic personal information
      • Name, date of birth, gender
      • Contact information such as address, telephone number, email address, SNS, etc.
      • Occupation and place of employment information
      • Information about your family (including names, addresses, dates of birth, and contact information)
      • Other personal information obtained from personal information obtained from service users, applicants, or contractors in this transaction
   2. (B)Information obtained from various contracts, reservations, applications, facility and service use, etc., in this Transaction, usage history information, and purchase history information
      • Information obtained from various contracts, reservations and applications (date and time, amount, details, application channel, etc. related to the contract, etc.)
      • Information obtained from the use and purchase of each facility and service (card information, point information, service usage history, product purchase history, etc.)
      • Participation information for special events, events, campaigns, etc.
   3. (C)Service usage history information and access log information for this transaction
      • User ID, application used, start date and time, operation log, cookie, cache ID, access date and time, access log, and other usage history and access log information
   4. (D)Opinions, inquiries and their history, information related to transaction needs, and other information acquired incidental to the provision of services in this transaction
      • Surveys, chats, conversation information, etc.
2. BScope of joint users
   Our Group
   https://www.seibuholdings.co.jp/group/grouplist/
3. CPurpose of use of information provided by joint users
   1. (A)To provide login services
      Example: "To enable you to log in using your ID to services provided by group companies."
   2. (B)For marketing and analysis
      Example: "For product development, customer trend analysis, market research, etc. related to our group's products and services."
   3. (C)For advertising and promotion
      Example: "For sales promotion activities, such as various information on sales and products provided by our group."
      Example: "To provide various information related to products and services provided by third parties affiliated with our group."
   4. (D)For service improvement and research and development
      Example: "To conduct surveys related to improving our services, such as surveys on the usage and satisfaction of services and products provided by our group."
   5. (E)To respond appropriately to contact, inquiries, etc.
      Example: "To contact ID holders who have applied for events or contests that are held jointly or in cooperation with our group."
      Example: "To respond to opinions and requests from ID holders who use the services provided by our group."
      Example: "Contacting ID holders, etc., necessary for transactions and confirming transaction details from our group"
   6. (F)To provide our group's services
      Example: "To provide services and after-sales services that are jointly or collaboratively provided by group companies."
      Example: "The Group will provide preferential services such as point services.
4. DPerson in charge of managing joint use
   Person in charge of managing joint use
   Name: Seibu Holdings Inc.
   Address: 1-16-15 Minami-Ikebukuro, Toshima-ku, Tokyo
   Representative: President and CEO Ryuichiro Nishiyama

3.Provision of personal information to third parties

1. (1)Except when required by law or other special reasons, the Company will not disclose or provide personal information of ID holders, etc. to third parties without the consent of the ID holders, etc.
2. (2)We may entrust the handling of personal information to a third party within the scope of the purpose of use notified or publicly announced. In such cases, we will obligate the entrusted party by contract to properly manage the information in accordance with laws and regulations, and will endeavor to supervise the appropriate protection and management of personal information.

4.Handling of Anonymously Processed Information

1. (1)Compliance with relevant laws, regulations, guidelines, etc.
   When handling anonymously processed information, we will comply with the Personal Information Protection Act, other laws and regulations, the "Guidelines for the Act on the Protection of Personal Information" and other guidelines.
2. (2)Matters concerning safety control measures
   When handling anonymously processed information, the Company will take necessary and appropriate safety control measures to prevent the leakage, loss, or damage of the anonymously processed information and information on the processing method, etc. (hereinafter referred to as "anonymous processed information, etc.") In addition, the Company will provide necessary and appropriate supervision to employees and contractors (including subcontractors, etc.) who handle anonymously processed information, etc.
3. (3)"Items of personal information" included in the anonymously processed information created by our company
   When creating anonymously processed information, the Company will make public the items of personal information contained in the created anonymously processed information.
4. (4)Provision to third parties
   When providing anonymously processed information to a third party, the Company will publicly announce the items of information concerning individuals contained in the anonymously processed information to be provided and the method of provision, and will clearly indicate to the third party that the information is anonymously processed information.

5.Pseudonymized information

1. (1)Compliance with applicable laws, regulations, guidelines, etc.
   • We will comply with the Personal Information Protection Act, other laws and regulations, as well as the "Guidelines on the Act on the Protection of Personal Information" and other guidelines, and will handle pseudonymized information and deleted information, etc. (hereinafter referred to as "pseudonymized information, etc.") appropriately.
   • When handling pseudonymized information, we will not use contact information or other information contained in the pseudonymized information to contact the individual whose personal information was used to create the pseudonymized information.
   • When the Company no longer needs to use the Pseudonymized Information, etc., it will endeavor to delete such Pseudonymized Information, etc. without delay.
2. (2)Matters concerning safety control measures
   We will take necessary and appropriate safety control measures to manage Pseudonymized Information, etc., including preventing leakage, loss, or damage. We will also provide necessary and appropriate supervision to employees and contractors (including subcontractors, etc.) who handle Pseudonymized Information, etc.
3. (3)Purpose of use of pseudonymized information
   Except as required by law, the Company will process pseudonymized information for the following purposes:
   1. (A)For marketing and analysis
      Example: "For product development, customer trend analysis, market research, etc. related to our group's products and services."
   2. (B)For service improvement and research and development
      Example: "To conduct surveys related to improving our services, such as surveys on the usage and satisfaction of services and products provided by our group."
4. (4)Provision to third parties
   We will not provide any pseudonymized information, etc. that we create or hold to any third party, except as permitted by law.
5. (5)Joint Use
   We will jointly use the pseudonymized information as follows:
   1. (A)Items of pseudonymized information to be jointly used
      Information that has been processed so that the personal information described in 2A above cannot identify a specific individual
   2. (B)Scope of parties using the information jointly
      Our Group
      https://www.seibuholdings.co.jp/group/grouplist/
   3. (C)Purpose of use by the user
      • For marketing and analysis
        (Example) "For product development, customer trend analysis, market research, etc. related to our group's products and services."
      • For service improvement and research and development
        (Example) "To conduct surveys related to improving our services, such as surveys on the usage and satisfaction of the services and products provided by our group."
   4. (D)Person in charge of managing joint use
      The person in charge of management as prescribed in 2E above

6.Disclosure, correction, and deletion of retained personal data

ID holders, etc. may request that we disclose personal information about them that is held by our company. If ID holders, etc. request the disclosure, correction, deletion, etc. of personal information about themselves that is held by our company, please make a request to the personal information inquiry desk described below. In addition, for procedures for disclosure requests, etc., please refer to the "Procedures for Disclosure, etc. of Personal Information" described at the end of this document.

7.Addition or change of purpose of use

We will use personal information within the scope of the purpose notified or publicly announced. If we use the information beyond the scope of the purpose, we will notify you to that effect.

8.Establishment of management system

1. (1)In order to prevent the loss, destruction, falsification, and leakage of personal information, we will establish a system for the appropriate management of personal information. In addition, we will not disclose or provide personal information to third parties without the consent of the ID holder, etc., unless there is a special reason, such as a legal request or cooperation with a government agency.
2. (2)Except when the ID holder, etc. has given consent or when required by law, etc., when providing all or part of personal information to a third party, we will do so with the consent of the ID holder, etc. In such cases, we will obligate the third party by contract to properly protect and manage personal information in accordance with the law.
3. (3)We may outsource the handling of personal information to a third party within the scope of the publicly announced purpose of use. In such cases, we will obligate the outsourcee by contract to properly manage the information in accordance with laws and regulations, and will endeavor to supervise the appropriate protection and management of personal information.
4. (4)We will strive to properly manage personal information, including by educating employees and staff on how to handle personal information.
5. (5)We will comply with laws, regulations, and standards regarding personal information protection, and act in accordance with our internal regulations regarding personal information protection.
6. (6)We will continually review and strive to improve our internal regulations and management system for personal information protection in accordance with changes in social conditions.
7. (7)We will respect the rights of ID Holders, etc. regarding their personal information, and when an ID Holder, etc. requests the disclosure, correction, deletion, etc. of his/her personal information, we will respond to such requests within a reasonable period of time and to an appropriate extent.

9.Personal Information Inquiry Desk

If you have any questions or comments regarding our handling of personal information, anonymously processed information, etc. and pseudonymously processed information, etc., please contact us at the following address.

SEIBU PRINCE CLUB Desk Personal Information Inquiry Desk
2F, 5-2019-7 Miharacho, Tokorozawa City, Saitama Prefecture, 359-0045
04-2929-0011

Procedures for disclosure of personal information

If an ID Holder, etc. wishes to change the purpose of use, disclosure, correction, addition, or deletion (hereinafter referred to as "Correction, etc."), suspension of use or erasure (hereinafter referred to as "Suspension of Use, etc."), or suspension of provision to a third party (hereinafter collectively referred to as "Disclosure, etc."), please make a request according to the following procedure.

1.Personal data held and subject to disclosure, etc.

The retained personal data that is subject to disclosure, etc. will be limited to basic information such as the individual's address and name, the Company's purpose of use, as well as information that is included in the retained personal data and that has been collected and is currently in the Company's possession (disclosure includes records of provision to third parties).

2.Contact details for requests for disclosure, etc. and inquiries

For requests based on our procedures for disclosure of personal information, or questions or comments regarding these procedures, please contact the point of contact listed in "Seib Smile ID Basic Policy for Personal Information Protection, 9. Personal Information Inquiry Point of Contact."

3.Documents and forms to be submitted when requesting disclosure, etc. (hereinafter referred to as "request forms")

Select the appropriate request form based on the purpose of your request and mail it to the contact point listed in "SEIBU Smile ID Basic Policy on Personal Information Protection, 9. Contact Point for Personal Information Inquiries." If you submit a request to the "Seibu Prince Club Desk Personal Information Inquiries" above, we will mail you a request form. Please fill in the required fields yourself and affix your seal. If a request is made by a representative, only the representative specified in the Personal Information Protection Act (hereinafter referred to as the "representative") may request disclosure, etc.
Please enclose the necessary documents, write "Personal Information Disclosure Documents Enclosed" in red ink on the envelope, and send your request by mail to our "Personal Information Inquiry Desk" listed above. We recommend that you use registered mail for safer mailings.
Requests for disclosure, etc. will only be accepted by mail. Please note that we cannot accept requests to visit our company in person.
*All expenses such as copying fees, costs of obtaining identity verification documents, and postage fees must be borne by the ID holder.
*Please note that any documents submitted when making a request for disclosure, etc. (including identity verification documents; hereinafter referred to as "application documents") will not be returned.

A.Our designated invoice
Request form for notification of purpose of use of personal information
Personal Information Disclosure Request Form
Personal information correction request form
Request form for suspension of use of personal information, etc.
Request for suspension of provision of personal information to third parties
*If there are any blanks, typos, or unclear parts in the required fields of each request form, or if there are any other imperfections in the description, we may contact the contact information you provided on the request form to confirm. If we are unable to confirm within two weeks of starting contact or if you do not resubmit (including cases where the request has not yet arrived), we will assume that no request for disclosure, etc. has been made. In this case, we will return all documents submitted by mail with a designated recipient. Please note that handling fees will not be refunded.


B.Documents for identity verification
Please submit a copy of either document a or b below as a document to verify your identity. Copies must include your name, address, and date of birth. When making a copy, please cover any parts of the document other than your name, address, and date of birth, such as "registered domicile" and "medical record," with paper or something similar.

a.Either one will suffice (official photo ID with valid validity)

• driver's license
• Japanese passport
• My Number Card

b.Two items you need to prepare (an official ID without a photo or other valid ID)

• Family register extract
• Copy of residence certificate (issued within the last 3 months)
• Nursing care insurance card
• Insurance certificates for various insurances
• National Pension Book
• Pension certificate
• Copy of alien registration card
• Photo ID (including date of birth)
• Student ID with photo (including ID card)
• Certificate of employment etc. (including the above)

*If the individual's current address differs from the address registered with our company due to relocation, etc., we ask that you submit a certificate of residence showing your relocation history.
*If identity verification documents are not enclosed or there are unclear parts of the identity verification documents, we will contact the contact information you provided on the request form to confirm. If we are unable to confirm within two weeks of the start date of contact or if you do not submit the documents again (including cases where they have not yet arrived), we will assume that no request for disclosure, etc. has been made. In this case, we will return all documents submitted by mail with a designated recipient. Please note that fees will not be refunded.

4.When a request for disclosure, etc. is made by an agent

If the person making the Disclosure, etc. request is the legal representative of the person in question or an agent delegated by the person in question, please enclose the following document (C or D) in addition to the above "A. Our designated request form."

C.In case of legal representative

1. C-1In case of legal representative of minor
   • Notification form prescribed by our company
   • Documents to confirm legal representation
   • If the person has parental authority, the person's family register extract or resident card (either one)
   • In the case of a guardian of a minor, the person's family register extract or resident's card (either one)
   • Documents to verify identity of the legal representative of a minor (same as "B. Documents to verify identity" above)
2. C-2In the case of a legal representative of an adult ward
   • In the case of a legal representative of an adult ward
   • Certificate of registration prescribed in Article 10 of the Guardianship Registration Act
   • Documents to verify the identity of the legal representative of the adult ward (same as "B. Documents to verify identity" above)

D.In the case of a delegated agent

• One power of attorney as specified by our company
• One set of documents to verify the identity of the authorized representative (same as "B. Documents to verify the identity" above)

*If a proxy will receive the results of disclosure, etc. from our company, please write in the power of attorney that you "delegate the authority to receive the results of disclosure, etc." In this case, the power of attorney must be stamped with the principal's official seal and the principal's seal certificate must also be submitted. Please note that if you do not write in the power of attorney that you are delegating the authority to receive the results of disclosure, affix your official seal, or submit a seal certificate, our company will provide the results of disclosure, etc. to the principal.
*If the procedure cannot be completed due to a lack of or insufficient documents to verify the power of attorney (including documents verifying the identity of the agent), it may not be possible to verify the identity of the person or the agent. In such cases, we will contact the contact information you provided on the request form to confirm. If we do not receive confirmation or resubmission (including cases where the documents have not yet arrived) within two weeks from the start of contact, we will consider the request for disclosure, etc. to have been rejected. We will return all documents submitted by mail that can only be received by the person in question. Please note that in this case, the handling fee will not be refunded.
*Only the person himself/herself or the agent who made the disclosure request can be designated as the recipient of the results of the disclosure, etc. If an agent is designated as the recipient, the Company shall not bear any responsibility if the person himself/herself is unable to receive the results of the disclosure, etc., regardless of the reason.

5.Postage costs and delivery method for requests for disclosure, etc.

A.When requesting disclosure or notification of purpose of use
If you wish to receive a response by mail, please enclose 624 yen worth of postage stamps for each request with your application documents.
*Fees for requests for disclosure, etc. are subject to change.
*If there are insufficient postage stamps for the fee, we will contact the contact address you provided on the request form. If we do not receive confirmation or resubmission (including non-delivery) within two weeks of the start date of contact, we will assume that no request for disclosure, etc. was made. We will return all submitted documents, etc. by personal delivery mail. Please note that in this case, we will not refund the fee.

B.In the case of a request for correction, suspension of use, or suspension of provision to a third party
If you specify the personal data held and then request correction, etc., suspension of use, etc., or suspension of provision to a third party, no fee will be charged. However, if you are unable to specify the personal data held, you may need to take steps to request disclosure in order to specify the personal data held for which you are requesting correction, etc., suspension of use, etc., or suspension of provision to a third party.

6.How to respond to requests for disclosure, etc.

In the case of a request for disclosure, we will respond using the method specified in the request form. However, if there are circumstances that would require excessive costs to respond using the method specified, we will respond by mail. In this case, we will also respond with the reason why we cannot respond using the method specified. In addition, in the case of a request other than disclosure, if we are to respond, we will respond by mail. Please note that it will take approximately two weeks from the start of the disclosure procedure to a response.
Please also note that if our counters are busy or there are other operational reasons related to our company, our response may be delayed even further.
Please note that if after we have sent our written response as described above, the response does not arrive due to a postal accident or other reason, we will not be held responsible unless the reason is due to our responsibilities.

7.When Disclosure, etc. is Not Made

Even if we receive a request for disclosure, etc., we will not disclose the requested information in the following cases. In this case, we will notify you of the reason. Please note that we will not refund the fee even if we do not disclose the information.

• If we are unable to verify that the request is coming from you, for example if the address on the invoice does not match the address on the identity verification document or the address registered with our company
• When a request is made by a representative, the authority of the representative cannot be confirmed
• If there is a problem with the application documents you submitted (including cases where there is a problem and you do not resubmit the documents even after we contact you).
• If the personal information requested for disclosure, etc. does not fall under the "retained personal data" stipulated in the Personal Information Protection Act
• When there is a risk of harm to the life, body, property or other rights and interests of the person or a third party
• When there is a risk of causing significant disruption to the proper performance of our business
• When it violates other laws and regulations

8.Regarding the "purpose of use" of personal information provided to us in relation to requests for disclosure, etc.

The request form, identity verification documents, and other personal information submitted in order to request Disclosure, etc. will be handled only to the extent necessary to contact the person in question, confirm the request, etc., and to fulfill the request for Disclosure, etc.
We will store the identity verification documents you submit for three years from the date of receipt. After the storage period has elapsed, we will promptly delete the documents by appropriate means.

End
Revised on July 31, 2025