SEIBU PRINCE CLUB Privacy Policy
*This Privacy Policy is effective as of April 25, 2024.
1.SCOPE OF THIS PRIVACY POLICY
This privacy policy sets out how SEIBU HOLDINGS INC. (registered office: 1-16-15 Minamiikebukuro, Toshima-ku, Tokyo 171-0022, Japan; "SEIBU Holdings") and SEIBU PRINCE HOTELS WORLDWIDE INC. (registered office: 1-16-15 Minami Ikebukuro, Toshima-ku, Tokyo 171-0022, Japan; "SPW" and together with SEIBU Holdings, "we", "us", "our") use personal data in relation to the SEIBU PRINCE CLUB and the Seibu Prince Global Rewards.
2.ABOUT US
The SEIBU PRINCE CLUB is SEIBU Holdings' rewards programme which will elevate your experience as you accumulate points based on each transaction and receive recommendations, discounts and special offers tailored just for you. The Seibu Prince Global Rewards is a sub-programme attached to the SEIBU PRINCE CLUB which provides you with benefits, recommendations, discounts and special offers relating to Seibu Prince Hotels & Resorts branded hotels and facilities and it is jointly operated by SEIBU Holdings and SPW. In order for us to provide the services and run the programme, we use personal data.
3.WHOSE PERSONAL DATA DO WE USE?
3.1 What personal data do we collect and use?
We typically process the following types of personal data about you:
(a) Contact details and basic registration information for the programme (such as email address, residential address, phone number, name, gender, date of birth, customer account number and lifestyle information)
(b) Transactional data relating to any purchase of products and services at the SEIBU PRINCE CLUB participating retailers and Seibu Prince Hotels & Resorts branded hotels and leisure facilities
We do not collect any of your special category data; this is any information relating to your health or medical records, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership.
3.2 How do we obtain your personal data?
We obtain your personal data in a number of different ways:
(a) The SEIBU PRINCE CLUB participating retailers andSeibu Prince Hotels & Resorts branded hotels and leisure facilities;
(b) third parties with your request (e.g. eligible rewards point exchange partners);
(c) trusted suppliers (e.g. payment providers, marketing agencies);
(d) IT systems, including via our platform;
(e) cookies on our website;
(f) government agencies;
(g) insurance companies;
(h) professional advisors including external legal advisors;
(i) IT service providers; or
(j) our regulators.
3.3 For what purpose do we use your personal data and with whom is it shared?
We process your personal data for a number of different purposes and under data protection laws, we must have a "lawful basis" to do so. We rely on the following 'lawful bases' when processing your personal data:
(a) to comply with our legal and regulatory obligations;
(b) it is necessary for the performance of our contract with you or to take steps at your request before entering into a contract;
(c) as necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
(d) where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests; or
(e) we have your consent.
Please see below for further details of the different ways we use your personal data, the lawful bases we rely on when doing so and details of whom we may share your personal data with:
| Who will process your personal data | Purpose for processing your personal data | Legal basis for processing your personal data | With whom do we share your personal data | What personal data will be shared with them (except administrative services providers and IT service providers)? |
|---|---|---|---|---|
| SEIBU Holdings | Administration of the SEIBU PRINCE CLUB | We have a contractual obligation | The SEIBU PRINCE CLUB participating retailers (including Seibu Prince Hotels & Resorts branded hotels and facilities) | Any information (set out in section 3.1) you request us to share with The SEIBU PRINCE CLUB participating retailers (including Seibu Prince Hotels & Resorts branded hotels and facilities) |
| SEIBU Holdings | Provision of benefits under the SEIBU PRINCE CLUB | We have a contractual obligation | [The SEIBU PRINCE CLUB participating retailers (including Seibu Prince Hotels & Resorts branded hotels and facilities)] Administrative services providers (including SEIBU Process Innovation) IT service providers | Any information (set out in section 3.1) you request us to share with The SEIBU PRINCE CLUB participating retailers (including Seibu Prince Hotels & Resorts branded hotels and facilities) |
| SEIBU Holdings and SPW | Administration of the Seibu Prince Global Rewards | We have a contractual obligation | Seibu Prince Hotels & Resorts branded hotels and facilities Administrative services providers (including SEIBU Process Innovation) IT service providers | Any information (set out in section 3.1) you request us to share with Seibu Prince Hotels & Resorts branded hotels and facilities In addition, where you put in your membership details on a booking site of any Seibu Prince Hotels & Resorts branded hotel or facility, to facilitate your booking process, your basic personal details (such as name and contact details) will be automatically shared with such hotel or facility |
| SEIBU Holdings and SPW | Provision of benefits under the Seibu Prince Global Rewards | We have a contractual obligation | [Seibu Prince Hotels & Resorts branded hotels and facilities] Administrative services providers (including SEIBU Process Innovation) IT service providers | Any information (set out in section 3.1) you request us to share with Seibu Prince Hotels & Resorts branded hotels and facilities |
| SEIBU Holdings and SPW | Promotional, marketing and business development | Your consent | Administrative services providers (including SEIBU Process Innovation) IT service providers | N/A |
Please note that we will keep your personal data confidential and will only share it (in the ways described above) where necessary. When we appoint third party service providers who act as processors on our behalf, we require them to comply with strict contractual obligations (which restrict their uses) and data protection laws.
We may also aggregate and pseudonymise personal data and use and share such aggregated and pseudonymise personal data with our group companies for statistical purposes and for the purpose of data analytics, service development, and/or improvement. A list of our current group companies is available here: https://www.seibuholdings.co.jp/en/group/grouplist/
We typically use the following types of data to divide customers in segments or groups to aggregate and pseudonymise personal data:
・residential address
・phone number
・gender
・date of birth
・customer account number
・lifestyle information
・Transactional data relating to any purchase of products and services at the SEIBU PRINCE CLUB participating retailers and Seibu Prince Hotels & Resorts branded hotels and leisure facilities
4.HOW DO WE PROTECT YOUR PERSONAL DATA WHEN SENDING IT ABROAD?
4.1 There will be some circumstances in which we will need to transfer your personal data outside of Japan. Where your personal data is transferred to any jurisdictions other than the UK and/or the European Economic Area (which means all the European Union (EU) countries plus Norway, Iceland and Liechtenstein, together "EEA"), we take steps to ensure that your personal data is adequately protected and in compliance with data protection laws.
4.2 A summary of our regular international data transfers are set out below:
| Country/jurisdiction to where we transfer personal data | Purpose for the transfer | Safeguard used to protect your personal data (except any transfers to the United Kingdom and EEA) |
|---|---|---|
| Australia, the United Kingdom, United Arab Emirates, the United States of America (mainland), Hawaii, Vietnam, Singapore, India, Bahrain, Indonesia, Thailand, China, Taiwan | For the purposes set out in the table in section 3.3 in relation to Seibu Prince Hotels & Resorts branded hotels and facilities located outside of Japan | Approved mechanisms for cross-border transfer including UK's International Data Transfer Agreement and EU's standard contractual clauses |
For further information on our transfers of personal data, please contact us at the contact details provided in the "Contacting Us" section below (see section 11).
5.WHAT MARKETING ACTIVITIES DO WE CARRY OUT?
5.1 We may from time to time provide you with information about our services or products or those of the SEIBU PRINCE CLUB participating retailers and Seibu Prince Hotels & Resorts branded hotels and leisure facilities which we think will be of interest to you or which you have asked us to provide you with. This may be sent by email or via the SEIBU PRINCE CLUB apps and the Seibu Prince Global Rewards apps.
5.2 We ensure that our marketing activities comply with all applicable law. In some cases, this may mean that we ask for your consent in advance of sending you marketing materials by email.
5.3 Please note that you can opt out of receiving any marketing communications at any time. An "unsubscribe" link appears in all our marketing emails. To unsubscribe from emails sent by us, simply click on the link at any time. Alternatively, you can contact us to update your preferences using the contact details in the "Contacting Us" section below (see section 11). In such circumstances, we will continue where necessary to send you service related communications as these will not constitute marketing communications.
6.AUTOMATED DECISION MAKING
Automated decision making refers to a situation where a decision is taken using personal information that is processed solely by automatic means (i.e., using an algorithm or other computer software) rather than a decision that is made with some form of human involvement. We use personal information to divide large groups of customers into sub-groups based on some type of shared characteristics such as geography, behaviour, or demographics. We make automated decisions, using segmentation and/or your specific personal information to offer you certain benefits, recommendations, discounts and special offers based on your characteristics.
7.YOUR RIGHTS
7.1 You have the right to make certain requests of us in relation to the personal data that we hold about you. If you wish to exercise these rights at any time please contact us using the details set out in the "Contacting us" section (see section 11).
7.2 Please note that not all of your data subject rights will be absolute; this means that there may be some circumstances where we may not be able to comply with your request (such as where this would conflict with our obligation to comply with other regulatory and/ or legal requirements). However, if we cannot comply with your request, we will tell you the reason, and we will always respond to any request you make.
7.3 There may also be circumstances where exercising some of these rights (such as the right to erasure, the right to restrict processing and the right to withdraw consent) will mean we can no longer provide you with our services and it may therefore result in the cancellation of our agreement with you. We will inform you of these consequences when you exercise your right.
7.4 For UK/EEA residents, your rights under data protection laws in the UK and EU are:
(a) the right to access your personal data:
(i) you are entitled to a copy of the personal data we hold about you and certain details of how we use it; and
(ii) we will usually provide you with your personal data in writing, unless you request otherwise, or where you have made the request using electronic means, in which case the information will, where possible, be provided to you by electronic means;
(b) the right to rectification: we take reasonable steps to ensure that your personal data that we hold is accurate and complete, however, you can ask us to amend or update the personal data if you do not believe that this is so or if your details change;
(c) the right to erasure: you have the right to ask us to erase your personal data in certain circumstances, for example where you withdraw your consent or where the personal data we obtained is no longer necessary for the original purpose; this right, will, however, need to be balanced against other factors, for example, we may have legal obligations which mean we cannot comply with your request;
(d) the right to restrict processing: in certain circumstances, you are entitled to ask us to stop using your personal data, for example where you think that we no longer need to use your personal data or where you think that the personal data we hold about you may be inaccurate;
(e) the right to data portability: you have the right, under certain circumstances, to ask that we transfer personal data that you have provided to us to another third party of your choice;
(f) the right to object to marketing: you can ask us to stop sending you marketing messages at any time. You can exercise this right by either clicking on the "unsubscribe" link which is contained in any email that we send to you or you can use the details set out in the "Contacting us" section to contact us (see section 11). Please note that exercise of this right does not extend to service related communications which, where necessary, we will continue to send;
(g)the right to object to processing: where we process your personal data based on our legitimate business interests (indicated in this privacy policy), you can object to our processing. We will consider your objection and determine whether or not our legitimate business interests prejudice your privacy rights;
(h) the right to withdraw consent: we may ask for your consent for certain uses of your personal data – we have indicated in this privacy policy where we do need your consent. You have the right to withdraw your consent at any time; and
(i) the right to lodge a complaint with the applicable data protection supervisory authority: we encourage you to contact us (using the details in the Contacting Us section (see section 11)) if you have any concerns with how we use your personal data and we will do our best to resolve your concerns. However, please note that you have a right to complain to the applicable data protection supervisory authority (depending on your territory) if you believe that any use of your personal data by us is in breach of applicable data protection laws.
Please note that lodging a complaint will not affect any other legal rights or remedies that you have.
8.HOW WE PROTECT YOUR PERSONAL DATA
8.1 We have put in place:
(a) appropriate security measures and policies and procedures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed; and
(b) procedures to address any suspected personal data breaches and we will notify you and any applicable regulator of a breach where we are legally required to do so.
8.2 Where we have given you (or you have chosen) a password, you are responsible for keeping this password confidential. Please do not share your password with anyone.
8.3 We review our security measures periodically. We also ensure that our employees receive appropriate data security training.
9.HOW LONG DO WE KEEP YOUR PERSONAL DATA?
9.1 We will only keep your personal data for as long as is necessary to fulfil the relevant purposes as set out in this privacy policy and more widely to comply with our legal and obligations for example for tax purposes.
9.2 The exact time period will depend on the type of personal data we hold; for example, we will maintain your membership registration details for as long as you have an account with the SEIBU PRINCE CLUB.
9.3 We may also aggregate and anonymise personal data and use and share such aggregated and anonymised personal data with third parties for statistical purposes and for the purpose of data analytics, service development, and/or improvement.
10.Responsible party for joint use of personal data and pseudonymised data within the meaning of Japanese data protection law
SEIBU HOLDINGS INC.
1-16-15 Minamiikebukuro, Toshima-ku, Tokyo 171-0022, Japan
President and Representative Director, President and COO NISHIYAMA Ryuichiro
11.CONTACTING US
If you have any queries about how we handle your personal data, the contents of this privacy policy, your data protection rights under applicable data protection laws, how to update your records or how to obtain a copy of the personal data that we hold about you, please contact us:
SEIBU PRINCE CLUB Desk, Contact Point for Personal Information Inquiries
5-2019-7 Mihara-cho, Tokorozawa-shi, Saitama 359-0045
Phone:04-2929-0011
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)
12.CONTACT DETAILS OF UK/EU REPRESENTATIVE
UK/EU REPRESENTATIVE
Data Protection Representative Limited
EMAIL ADDRESS
datarequest@datarep.com
When you send an email to Data Protection Representative Limited, please quote <SEIBU HOLDINGS INC.> or <SEIBU PRINCE HOTELS WORLDWIDE INC.> in the subject line.
ONLINE WEBFORM
http://www.datarep.com/data-request
ADDRESS
Please mail your inquiry to Data Protection Representative Limited at the most convenient of the addresses below.
PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ‘Data Protection Representative Limited’ and not ‘SEIBU HOLDINGS INC.’ or ‘SEIBU PRINCE HOTELS WORLDWIDE INC.’, or your inquiry may not reach us. Please refer clearly to SEIBU HOLDINGS INC. or SEIBU PRINCE HOTELS WORLDWIDE INC. in your correspondence. On receiving your correspondence, SEIBU HOLDINGS INC. or SEIBU PRINCE HOTELS WORLDWIDE INC. is likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.
| Country | Address |
|---|---|
| Austria | DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
| Belgium | DataRep, Place de L'Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium |
| Bulgaria | DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria |
| Croatia | DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus |
| Cyprus | DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus |
| Czech Republic | DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic |
| Denmark | DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark |
| Estonia | DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia |
| Finland | DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland |
| France | DataRep, 72 rue de Lessard, Rouen, 76100, France |
| Germany | DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany |
| Greece | DataRep, 24 Lagoumitzi str, Athens, 17671, Greece |
| Hungary | DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary |
| Iceland | DataRep, Kalkofnsvegur 2, 3rd Floor, 101 Reykjavík, Iceland |
| Ireland | DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland |
| Italy | DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy |
| Latvia | DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia |
| Liechtenstein | DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
| Lithuania | DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania |
| Luxembourg | DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg |
| Malta | DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta |
| Netherlands | DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands |
| Norway | DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway |
| Poland | DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland |
| Portugal | DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal |
| Romania | DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857,Romania |
| Slovakia | DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia |
| Slovenia | DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia |
| Spain | DataRep, Calle de Manzanares 4, Madrid, 28005, Spain |
| Sweden | DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden |
| United Kingdom | DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom |
13.UPDATES TO THIS PRIVACY POLICY
From time to time we may need to make changes to this privacy policy, for example, as the result of changes to applicable law, technologies, our services, or other developments. We will provide you with the most up-to-date privacy policy and you can check our website [INSERT WEBSITE LINK FOR PRIVACY POLICY] periodically to view it.
The text of this policy is given in English. In the event the policy is translated into languages other than English, only the English text shall be valid and text that has been translated into any other language will have no effect whatsoever.
This privacy policy was last updated on April 25, 2024.
