Basic Policy on the Protection of Personal Information

Seibu Holdings Inc. (hereinafter, "the Company") has established a philosophy behind its business activities under the Seibu Group Vision that states it will contribute to the development of society and local communities as well as the protection of the environment, and provide safe, secure and comfortable services. To fulfill this vision, the Company recognizes that as a member of society it is important to obtain the trust of customers, shareholders, employees and local communities. As such, one of the Company's most important management tasks today is the establishment of a compliance program.

The Company recognizes that proper handling of the personal information obtained from customers is an important compliance task. Therefore, the Company declares the following basic policy on the protection of personal information (the Seibu Prince Club is governed in accordance with the separately stipulated basic policy on the protection of personal information handled in the SEIBU Smile POINT program as well as campaigns and services conducted related to this program). The Company will also continually protect and improve its handling of personal information obtained through its business activities.
When handling specific personal information, the Company will give priority to items set forth in the "Basic Policy Concerning the Proper Handling of Specific Personal Information."

Basic Policy on the Protection of Personal Information

1. The Company uses personal information obtained from its customers according to the following purposes.

   1. To communicate and manage operations for business transactions
   2. To exercise contractual rights and fulfill contractual obligations
   3. To perform after-the-fact controls after the cancellation of a contract or cancellation of a business transaction
   4. To contact the customer in an emergency
   5. To smoothly execute a business transaction or contract
2. The Company will use personal information within the notified or published scope of purpose. If this information must be utilized beyond the scope of purpose, the Company will inform the customer.
3. The Company will establish a system to properly manage personal information to prevent the loss, destruction, modification or divulgation of personal information. In addition, the Company will not disclose or provide the customer's personal information to a third party without his or her consent, except when special reasons exist, such as a legal request or other.
4. The Company, when providing the customer's personal information outside the Company based on the consent of the said customer, will require by means of a contract that the recipient of such information implement controls similar to those of the Company.
5. The Company will strive to manage personal information appropriately by holding employee training on the handling of personal information as well as appointing a manager of personal information for each division and department handling personal information.
6. The Company will comply with laws and regulations related to the protection of personal information as well as act in accordance with internal rules on personal information stipulated by the Company.
7. The Company, based on changes in the state of society, will periodically review and improve its rules on the protection of personal information and its management system.
8. The Company respects the rights of customers concerning their personal information, and when a customer requests the disclosure, correction, or deletion of their personal information, the Company will respond within a reasonable time period and within a valid scope.
9. Contact point for inquiries on the Company's handling of personal information:
   SEIBU HOLDINGS INC.
   1-16-15 Minamiikebukuro, Toshima-ku, Tokyo 171-0022, Japan
   Tel: +81-3-6709-3100
   (9:00 a.m. to 4:00 p.m., excluding Saturdays, Sundays, and holidays [including December 30 to January 3])

Basic Policy Concerning the Proper Handling of Specific Personal Information

The Company sets forth this basic policy on ensuring the proper handling of individual numbers and specific personal information (hereinafter, "specific personal information, etc.") so that proper practice is ensured throughout the organization.

1. Collection and Utilization
   The Company will collect and utilize specific personal information, etc., only in cases of necessity and within the scope of administrative duties set forth by law.
2. Compliance with Related Laws, Ordinances and Guidelines, etc.
   The Company will comply with such laws as the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure, the Act on the Protection of Personal Information and the Guidelines for Proper Handling of Specific Personal Information (for private entities) to ensure the proper handling of specific personal information, etc.
3. Item Concerning Security Control Measures
   With regard to security control measures for specific personal information, etc., the Company will separately establish a management system based on internal rules for handling specific personal information, etc., and ensure that this system is operated properly.
4. Improvement
   The Company will strive to make continuous improvements to ensure that specific personal information, etc., is handled properly.
5. Contact for Comments and Queries, etc.
   Please direct comments and queries on the Company's handling of specific personal information, etc., to the following contact details.
   
   SEIBU HOLDINGS INC.
   1-16-15 Minamiikebukuro, Toshima-ku, Tokyo 171-0022, Japan
   Tel: +81-3-6709-3100
   (9:00 a.m. to 4:00 p.m., excluding Saturdays, Sundays, and holidays [including December 30 to January 3])