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Privacy Policy
Basic policy on protection of personal information
SEIBU RAILWAY Co., Ltd. (hereinafter, the Company) and the companies of the Seibu Group (SEIBU HOLDINGS INC. and its subsidiaries and affiliates; hereinafter, Group companies; the Company and Group companies are referred to collectively hereinafter as the Group) do business in accordance with the Group Vision calling for provision of safe, reliable, comfortable services while contributing to the progress of its communities and society and to environmental protection. Recognizing the importance of earning the trust of customers, shareholders, employees, and communities as members of society, they aim to establish a Groupwide compliance structure.
The Company recognizes the proper handling of personal information entrusted by customers to be an important compliance-related topic. Accordingly, the Company has established the following basic policy on protection of personal information, under which it strives to protect and continually improve personal information in Company business activities.
The provisions of the Basic Policy on Proper Handling of Specific Personal Information take precedence in handling of specific personal information.
1. Handling of personal information
The Company uses personal information provided by customers for the following purposes.
(1) For member services and provision of subject services
Ex.: For sales-promotion activities such as providing information on various subjects such as sales and product information provided by the Group
Ex.: To provide reward points and services associated with membership cards at affiliated stores and elsewhere
Ex.: To operate Interest reservations services
(2) To exercise rights and perform obligations under contracts etc.
Ex.: For application, membership/withdrawal, reservations for use, and various other procedures
Ex.: To exercise Group rights and perform Group obligations and for related handling
(3) In advertising, promotion, and marketing
Ex.: For use in product development, customer trend analysis, market research, etc. related to Group products and services
(4) For service improvements, surveys, and research and development
Ex.: To carry out surveys related to service improvements, such as those related to usage of and satisfaction with services and products provided by the Group
Ex.: To maintain security inside railway facilities and tourism facilities and in stores operated by the Company
Ex.: To maintain records of incidents occurring inside railway facilities and tourism facilities and in stores operated by the Company
(5) To respond appropriately to inquiries and other communications submitted to the Group
Ex.: To communicate with customers who have applied for events, prizes, etc. organized by the Group
Ex.: To respond to comments and requests from customers who use services provided by the Group
Ex.: For communication and verification related to reservations, sales, loss, reissue, refund, etc. of limited express tickets, retail passes, etc.
Ex.: For communication and verification related to lost-and-found articles
Ex.: For communication with residents of the areas along rail lines and near tourism facilities and users of Company tourism facilities
(6) For communication and verification with customers who have purchased casualty insurance and associated or related services contracted to the Company by insurers
(7) To contact customers in an emergency
(8) For cancellation of transactions and subsequent management
(9) For use for the purposes under 3(3) above
(10) To provide various types of information provided by third-party partners
Ex.: To provide various types of information related to products and services provided by third parties in partnership with the Group
(11) To provide personal information to third parties with customer consent, to the extent necessary to achieve the above purposes of use
2. Disclosure and provision of personal information to third parties
(1) The Company will not disclose or provide customer personal information to third parties without customer consent except in special cases such as those provided for under laws or regulations.
(2) The Company may entrust operations related to handling of personal information to third parties within the extent of communicated or published purposes of use. When doing so, it obligates the contractors to manage the information appropriately in accordance with laws, regulations, etc. and strives to supervise them to ensure that the personal information is protected and managed properly.
3. Joint use of personal information
The Company uses personal information obtained from customers jointly as described below.
(1) Items of jointly used personal information
(A) Basic personal information
✓ Name, date of birth, gender
✓ Address, tel. no., fax no., email address, social-media information, and other contact information
✓ Information concerning occupation and employer
✓ Family information (including names, addresses, dates of birth, and contact information)
✓ Other personal information obtained from service users, applicants, or contractual counterparties
(B) Information obtained from various contracts, reservations, applications, use of facilities and services, etc., usage history, and purchase history
✓ Information obtained from various contracts, reservations, and applications (e.g., date and time of concluding contract etc., amounts, details, application channels)
✓ Information from use and purchase of various facilities and services (e.g., credit-card information, rewards point information, service usage history, and product purchase history)
✓ Information on matters concerning billing and payment, including usage charges, credit cards, payment status, and payment dates
✓ Information on participation in activities, events, promotional campaigns, etc.
(C) Service usage history information, access log information
✓ Information concerning usage history and access logs, including user IDs, apps used, starting date and time, use logs, cookies, cache IDs, access date and time, access logs, etc.
(D) Vital information obtained from use of various services
✓ Height, weight, vital signs, images, audio, fingerprints, etc.
(E) Content and history of comments and inquiries, information on transaction needs, and other information obtained in connection with service provision
✓ Questionnaires, chat, conversational information, etc.
(2) Scope of joint users
(3) Purposes of use by joint users
(A) For marketing and analysis
Ex.: For use in product development, customer trend analysis, market research, etc. related to Group products and services
(B) In advertising and promotion
Ex.: For sales-promotion activities such as providing information on various subjects such as sales and product information provided by the Group
Ex.: To provide various types of information on products and services provided by third parties in partnership with the Group
(C) For service improvements and research and development
Ex.: To carry out surveys related to service improvements, such as those related to usage of and satisfaction with services and products provided by the Group
(D) To respond appropriately to inquiries and other communications submitted to the Group
Ex.: To communicate with customers who have applied for events, prizes, etc. organized by the Group jointly or in partnership with others
Ex.: To respond to comments and requests from customers who use services provided by the Group
Ex.: For communication and checking of transaction details with customers by the Group as necessary in transactions
(E) To provide the Group's services
Ex.: To provide services and follow-up care by Group companies jointly or in cooperation with each other
Ex.: To provide benefits such as rewards points and services by the Group
(F) To contact customers in an emergency
(4) Party responsible for management of joint use
Name: SEIBU RAILWAY Co., Ltd.
Address: 11-1 Kusunokidai 1-chome, Tokorozawa, Saitama Prefecture
Representative: Shuichiro Ogawa, President & CEO
4. Handling of anonymized information
(1) Compliance with applicable laws, regulations, guidelines, etc.
The Company handles anonymized information and information on methods of processing and other matters (hereinafter, anonymized information etc.) properly in accordance with the Act on the Protection of Personal Information and other laws and regulations and the Guidelines to the Act on the Protection of Personal Information and other guidelines.
(2) Information concerning security measures
The Company employs necessary and appropriate security measures to manage anonymized information etc., including measures to prevent information leaks, loss, and damage. It also employs necessary and appropriate supervision of employees and contractors (including subcontractors) who handle anonymized information etc.
(3) Items of information concerning individuals contained in anonymized information prepared by the Company
The Company prepares anonymized information from customers' personal information by processing it so that it cannot be used to identify individual customers. It plans to prepare similar anonymized information continuously in the future as well.
The following items of information concerning individuals are contained in anonymized information.
(A) Address (to the municipality level)
(B) Age (date of birth)
(C) Gender
(D) Tel. no.
(E) Email address
(F) Location
(G) Survey contents
(H) Membership nos. or other ID information
(I) Purchase history
(4) Provision to third parties
The Company continually provides to third parties anonymized information it prepares or holds, clearly indicating that such information is anonymized information.
(A) Items of information concerning individuals contained in anonymized information
The same items of information indicated under (3) above
(B) Method of providing anonymized information
Uploading by the Group to systems that enable use of anonymized information
5. Handling of pseudonymized information
(1) Compliance with applicable laws, regulations, guidelines, etc.
✓ The Company handles pseudonymized information and information on deletion and other matters (hereinafter, pseudonymized information etc.) properly in accordance with the Act on the Protection of Personal Information and other laws and regulations and the Guidelines to the Act on the Protection of Personal Information and other guidelines.
✓ When handling pseudonymized information etc., the Company does not use contact information and other information contained in such pseudonymized information for purposes such as contacting the individual concerned by the personal information used to prepare the pseudonymized information.
✓ The Company strives to delete pseudonymized information etc. without delay as soon as its use no longer is necessary.
(2) Information concerning security measures
The Company employs necessary and appropriate security measures to manage pseudonymized information etc., including measures to prevent information leaks, loss, and damage. It also employs necessary and appropriate supervision of employees and contractors (including subcontractors) who handle pseudonymized information etc.
(3) Provision to third parties
The Company does not provides to third parties pseudonymized information it prepares or holds, except as provided for by laws or regulations.
(4) Joint use
The Company uses pseudonymized information jointly as described below.
(A) Items of pseudonymized information used jointly
The personal information described under 3(1) above, processed so that it cannot be used to identify specific individuals
(B) Scope of joint users
The Group
(C) Purposes of use of users
✓ For marketing and analysis
Ex.: For use in product development, customer trend analysis, market research, etc. related to Group products and services
✓ For service improvements and research and development
Ex.: To carry out surveys related to service improvements, such as those related to usage of and satisfaction with services and products provided by the Group
(D) Party responsible for management of joint use
The party responsible indicated under 3(4) above
6. Disclosure etc. of retained personal data
A customer may ask the Company to disclose personal information concerning him or her held by the Company. Customers are requested to contact the personal information contact point shown below to request disclosure, correction, cessation of use, etc. of personal information concerning them held by the Company. See "Procedures for Disclosure etc. of Personal Information" below concerning procedures for requesting disclosure etc.
7. Addition of and changes to purposes of use
The Group uses personal information within the extent of communicated or published purposes of use. It will provide notification before using the information beyond the extent of these purposes of use.
8. Development of management structures
(1) Formulation of personal information protection guidelines
✓ These guidelines (personal information protection guidelines) are formulated regarding matters such as compliance with applicable laws, regulations, guidelines, etc. and contact points for questions and complaint resolution, to ensure that personal information is handled appropriately.
(2) Maintenance of rules on handling of personal information
✓ Internal rules on handling of personal information are formulated and management structures established regarding matters such as methods of handling, persons responsible and in charge, and their duties, at each stage including acquisition, use, storage, provision, and deletion/destruction.
(3) Organizational security measures
✓ Together with appointing persons responsible for handling of personal information, the scopes of employees handling personal information and the personal information they handle are made clear and structures are in place for reporting and communication to the persons responsible in the event that any violations of the Act on the Protection of Personal Information or internal rules on handling of personal information, or signs thereof, have been identified.
✓ Regular self-inspections as well as auditing by the internal section in charge are conducted regarding the state of handling of personal information.
(4) Human security measures
✓ Employees are provided with regular training on points to note in handling of personal information.
✓ The rules of employment include provisions on nondisclosure of personal information.
(5) Physical security measures
✓ Employee entrance and exit and devices and other items brought with them are restricted in zones handling personal information, and measures are taken to prevent unauthorized persons from viewing personal information.
✓ Measures are taken to prevent incidents such as theft or loss of devices, digital media, documents, etc. containing personal information, and when transporting such devices, media, etc., even within business sites, measures are taken to ensure that personal information cannot be identified easily.
(6) Technical security measures
✓ Access controls are employed to restrict personnel handling personal information and the scope of personal information databases and other resources that they handle.
✓ Systems are used to protect information systems used to handle personal information from unauthorized intrusion or malware.
(7) Responding to requests for disclosure etc.
✓ The Company respects the rights of customers concerning their personal information and responds to the appropriate extent and within a reasonable period of time, in accordance with the "Procedures for disclosure etc. of personal information" established separately, to any requests from customers for disclosure, deletion, suspension of use, etc. of their personal information.
9. Contact point for inquiries on personal information
Please direct any questions or comments concerning matters such as the Company's handling of personal information, specific personal information, and anonymized information to the following contact point:
Name: SEIBU RAILWAY Co., Ltd. Personal Information Inquiry Office
11-1 Kusunokidai 1-chome, Tokorozawa, Saitama Prefecture 359-8520
Tel.: (04) 2926-2691 (9:00-16:00; closed weekends, holidays, and over the year-end/New Year's holidays)
10. Use of Google Analytics
The Company uses Google Analytics to analyze access logs of visitors to its websites. It also uses data collected, recorded, and analyzed by Google. See the following site for information on matters such as use of Google Analytics on Company websites and the Google Analytics terms of use and privacy policy.
Basic Policy on Proper Handling of Specific Personal Information
The Company has established this Basic Policy uses to handle individual numbers and specific personal information (hereinafter, specific personal information etc.) properly as an organization.
1. Collection and use
The Company collects and uses specific personal information etc. only as necessary, within the extent of administration prescribed by laws and regulations.
2. Compliance with applicable laws, regulations, guidelines, etc.
The Company handles specific personal information etc. properly in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, the Act on the Protection of Personal Information, the Guidelines on Proper Handling of Specific Personal Information (for Businesses), etc.
3. Information concerning security measures
The Company employs appropriate security measures for specific personal information etc. under a management structure based on its separate internal rules on handling of specific personal information etc.
4. Improvements
The Company strives to make continual improvements to ensure that specific personal information etc. is handled appropriately,
5. Contact point for questions etc.
Please direct any questions or comments concerning the Company's handling of specific personal information etc. to the contact point shown under "8. Personal Information Contact Point" in the Privacy Policy.
Procedures for disclosure etc. of personal information
Customers who desire disclosure of purposes of use of their personal information or its disclosure, correction, addition, deletion (hereinafter, correction etc.), cessation of use or deletion (hereinafter, cessation of use etc.) or suspension of provision to third parties (referred to collectively as disclosure etc.) are requested to submit their requests through the following procedures.
1. Retained personal data subject to disclosure etc.
Retained personal data that are subject to disclosure etc. are limited to basic information such as individual names and addresses, the Company's purpose of use of information, and retained personal data that was collected and currently is retained by the Company (including records of provision to third parties).
2. Where to address requests for disclosure etc. and inquiries
Please direct any requests based on procedures for disclosure etc. of personal information held by the Company and questions or comments concerning these procedures to the contact point shown under "8. Personal Information Contact Point" in the Privacy Policy.
3. Documents and forms to be submitted when requesting disclosure etc. (hereinafter, request forms)
To requesting disclosure etc., prepare a request form in the Company's designated format and copies of any required identification documents.
Choose the designated request form appropriate for your request and mail it by post to the contact point shown under "8. Personal Information Contact Point" in the Privacy Policy. The personal information contact point above will send the request forms by post upon request. Fill out the necessary information on the form yourself and affix your seal. Disclosure etc. may be requested by proxy from only the agents specified in the Act on the Protection of Personal Information (hereinafter, agents).
Enclose the necessary documents in an envelope, write "Personal information disclosure documents enclosed" in red on the outside of the envelope, and submit the request by post to the Company's personal information contact point above. Use of registered mail is recommended as a more secure method of sending the documents.
Requests for disclosure etc. are accepted by post only. Note that they cannot be accepted if brought directly to the Company (including stations and all other business facilities).
* The customer must bear all associated costs, such as photocopying costs, costs of obtaining ID, and postage.
* Note that documents submitted when requesting disclosure etc. (including ID documents; hereinafter, request documents) will not be returned.
A. The Company's designated request forms
Request for notification of purposes of use of personal information
Request for disclosure of personal information
Request for correction etc. of personal information
Request for suspension of use of personal information
Request for suspension of provision of personal information to third parties
* If there is any discrepancy in the information on a request form, such as incompletion, incorrect information, or unclear information, the Company may contact the contact indicated on the request form to check on the information. The request for disclosure etc. will be invalid if the information cannot be verified or the requested information is not resubmitted (including nondelivery) within two weeks from the date the first attempt at contact was made. In such a case, the documents and other materials submitted will be returned to the applicant by registered mail deliverable to the addressee only. Note that any fees paid will not be refunded.
B. Identification documents
Submit copies of the documents under a or b below for identification. Copies must show the name, address, and date of birth of the individual to be identified. When making copies of the documents, block out using a sheet of paper or other means items of information other than name, address, and date of birth (such as permanent domicile or examination records).
a. Either of the following (valid photo ID)
- Driver's license
- Japanese passport
- Social Security and Tax Number card (front side only)
b. Two of the following (valid official ID without a photo)
- Official copy of family register
- Copy of certificate of residence (issued within the past three months)
- Long-term care insurance card
- Other insurance card
- National pension booklet
- Pension card
- Copy of certificate of alien registration
- Employee photo ID (showing date of birth)
- Student photo ID (showing date of birth)
- Certificate from employer etc. (showing date of birth)
* If the individual's current address differs from the address registered with the Company due to relocation or other reasons, submit a certificate of residence showing relocation records.
* If ID documents are not enclosed or are unclear, the Company may contact the contact indicated on the request form to check on the information. The request for disclosure etc. will be invalid if the information cannot be verified or the requested information is not resubmitted (including nondelivery) within two weeks from the date the first attempt at contact was made. In such a case, the documents and other materials submitted will be returned to the applicant by registered mail deliverable to the addressee only. Note that any fees paid will not be refunded.
4. Request for disclosure etc. by an agent
Enclose the documents below (under C or D) in addition to those under "A. The Company's designated request forms" above if the request for disclosure etc. is being made by a legal representative or proxy of the individual concerned.
C. Legal representative
C-1. Legal representative of a minor
- Documentation of authorization as a legal representative
･ Parent or guardian of the individual concerned: official copy of the individual's family register, the individual's certificate of residence (one of the above)
･ If the individual concerned is a minor ward: official copy of the individual's family register, the individual's certificate of residence (one of the above)
･ Proof that the applicant is the legal representative of the minor
(Same as under "B. Identification documents" above)
C-2. Legal representative of an adult ward
The Company's designated notice form
- Certificate of Registered Information under Article 10 of the Act on Guardianship Registration, etc.
- Proof that the applicant is a legal representative of the adult ward
(Same as under "B. Identification documents" above)
D. Proxy
The Company's designated letter of proxy
- Proof that the applicant is the proxy
(Same as under "B. Identification documents" above)
* To have the results of disclosure etc. from the Company received by the proxy, indicate on the proxy letter the fact that the proxy is authorized to receive the results of disclosure etc. When doing so, affix the registered seal of the individual concerned to the letter of proxy and submit the individual's seal registration certificate. Note that the Company will provide the results of disclosure etc. to the individual concerned if not all of the following are present: indication of the fact that the proxy is authorized to receive the results, registered seal impression, and seal registration certificate.
* It might not be possible to verify the individual or representative if procedures cannot be completed due to a deficiency or discrepancy in the documents for verification of authorization as representative (including the representative's ID documents). In such a case, the Company will contact the contact indicated on the request form. The request for disclosure etc. will be invalid if the information cannot be verified or the requested information is not resubmitted (including nondelivery) within two weeks from the date the first attempt at contact was made. In such a case, the documents and other materials submitted will be returned to the applicant by registered mail deliverable to the addressee only. Note that any fees paid will not be refunded.
* Results of disclosure etc. may be specified to be sent to only the individual concerned or the representative who made the request. The Company will not be liable for inability of the individual concerned to receive the results of disclosure etc., for any reason, when a representative was specified as the recipient of the results.
5. Postage and delivery methods related to requests for disclosure etc.
A. Requests for disclosure and notification of purposes of use
If requesting a response by post, enclose 774 yen in postage stamps per request with the request documents.
* Fees related to requests for disclosure etc. are subject to change.
* If the postage included is insufficient, the Company will contact the contact indicated on the request form. The request for disclosure etc. will be invalid if the information cannot be verified or the correct postage is not submitted (including nondelivery) within two weeks from the date the first attempt at contact was made. In such a case, the documents and other materials submitted will be returned to the applicant by registered mail deliverable to the addressee only. Note that any fees paid will not be refunded.
B. Requests for correction etc., requests for cessation of use etc., or requests for suspension of provision to third parties
No fees apply to requests for correction etc., requests for cessation of use etc., or requests for suspension of provision to third parties of identified retained personal data. If the retained personal data cannot be identified, it may be necessary to complete the procedures for a request for disclosure to identify the retained personal data subject to the request for correction etc., request for cessation of use etc., or or request for suspension of provision to third parties.
6. How we respond to requests for disclosure etc.
The Company will respond to requests for disclosure of retained personal data or disclosure of records of provision to third parties through the methods designated on the request form. However, we may respond by post in cases such as when responding by the designated method would be too costly. In such a case, we will provide with our response the reason why the designated method was not employed. If a response from the Company is necessary in a case of a request for disclosure etc. of information other than personal data held or disclosure of records of provision to third parties, we will respond by post. We will respond approximately two weeks after beginning procedures for disclosure etc.
Note that it may take longer to respond when the contact point is especially busy or due to other business-related circumstances affecting the Company.
Also note that the Company is not liable for nondelivery due to postal accidents or other causes after it has sent a written response, unless due to reasons for which the Company is responsible.
7. Cases in which disclosure etc. will not take place
The Company will not engage in disclosure etc. of the requested information in the following cases. In such a case, it will provide notice of the reason for refusing the request. Note that any fees paid will not be refunded even if the request for disclosure etc. is refused.
- When it cannot be verified that the request is from the individual concerned by the information, such as cases in which the addresses shown on the request forms, shown on ID documents, and registered with the Company do not match
- When the authorization of the representative cannot be confirmed in a case of a request made by a representative
- When there is a discrepancy in the request documents submitted (including cases in which the Company has notified the applicant of such discrepancy but the documents have not been resubmitted)
- When the personal information for which disclosure etc. is requested does not qualify as "retained personal data" under the Act on the Protection of Personal Information
- In cases that could endanger the life, health, property, or other rights and interests of the individual concerned or a third party
- In cases that could markedly impede proper business execution by the Company
- In other cases that would violate laws or regulations
8. Purposes of use of personal information received by the Company in connection with requests for disclosure etc.
Personal information on request forms, ID documents, and other documents submitted to request disclosure etc. will be used solely within the extent necessary for responding to the request for disclosure etc., such as to communicate and check information with the individual concerned by the request.
The Company will retain ID documents submitted for three years from the date they were received. It will delete them promptly, through appropriate means, after this period has expired.
End of document
Updated October 1, 2023.