Policy for Handling of Facial Recognition Data

Users (hereinafter “the Customer”) of the smartphone application, “Prince Smart Inn App” (hereinafter, “the App”), provided by SEIBU PRINCE HOTELS WORLDWIDE INC. (hereinafter “the Company”) are able to use check-in and other services (hereinafter “the Services”) that employ a facial recognition system inside the App.
For the use of the Services, the following provisions shall apply regarding the handling of Facial Recognition Data (stipulated in Article 2) that the Customer registers in said facial recognition system.
For the use of Services in the App other than the handling of Facial Recognition Data, the Prince Smart Inn App Terms of Service shall apply. For handling of Facial Recognition Data not included in this Handling Policy, the Company’s Privacy Policy shall apply.

Article 1. Use of the system
In providing the Services to the Customer in the App, the Company uses the services of the following business entity that employ a facial recognition system.
（１）Business entity:NEC Corporation (hereinafter “NEC”)
（２）Name of service:NEC Smooth check-in Service

Article 2. Facial recognition data obtained

1. In the event of the use of the Services by a Customer, the Company will obtain the facial photograph/facial recognition data (hereinafter “Facial Recognition Data”) registered by the Customer for the use of the Services.
2. The use of the Services is voluntary, and the Customer is still able to patronize the hotel without using the Services.

Article 3. Purposes for which Facial Recognition Data is used
The Company uses the Facial Recognition Data for the following purposes.
(1) For the provision of hotel check-in services
(2) For the provision of hotel guest room key services
(3) For system maintenance of the Services
(4) To prevent unauthorized acts or potentially illegal acts
(5) For the provision to third parties stipulated in the following article

Article 4. Provision of Facial Recognition Data to third parties, etc.
The Company will not engage in the joint use of Facial Recognition Data or provide or disclose it to third parties without the consent of the Customer. However, the Company may provide the Facial Recognition Data to a third party where the disclosure of personal information is required by laws, rules, or legal procedures or at the demand of a public or government agency, either in or outside the Customer’s country of residence, where it is required for national security, enforcement of the law, or the realization of other public interest, where sub-contracting the handling of Facial Recognition Data based on the following article, or on the basis of other legislation.

Article 5. Subcontracting of handling of Facial Recognition Data

1. The Company will subcontract the handling of Facial Recognition Data to NEC to conduct the operations within the scope of the purposes of use stipulated in Article 3. NEC may further sub-subcontract such handling to NEC Solution Innovators, Ltd., NEC Networks & System Integration Corporation, NEC Fielding, Ltd. or other NEC Group companies or partner corporations.
2. The obligation to manage Facial Recognition Data strictly to the same standard as the Company will be imposed on the subcontractor and the necessary and appropriate supervision of the subcontractor will be conducted.

Article 6. Security management measures

1. The Company makes every effort to manage Facial Recognition Data strictly with preventive and security measures to protect against unauthorized access, loss, destruction, tampering, and leaks.
2. The retention period for the Facial Recognition Data shall be one (1) year from registration, and the Facial Recognition Data will be automatically deleted after the conclusion of the retention period (or at the time of termination if the Company terminates the provision of the App or the Services). However, the Customer is able to delete the registration of their Facial Recognition Data from within the App at any time, even during the retention period.

Article 7. Revision and publication of this Handling Policy
This Handling Policy may be revised at any time in response to revisions or amendments to relevant laws or regulations and to the needs of society concerning personal information. In such an event, the Company will publicize the revision inside the App without delay and clearly state the latest date of revision of the Handling Policy.

Article 8. Contact for inquiries concerning Facial Recognition Data
For inquiries, advice, or disclosure, etc. (disclosure, revision, deletion, suspension of use, etc.) of Facial Recognition Data, please contact the following.

< Contact for inquiries concerning Facial Recognition Data >
Personal Information Inquiries, Sales & Marketing Department, SEIBU PRINCE HOTELS WORLDWIDE INC.
3-1-5 Higashi Ikebukuro, Toshima-ku, Tokyo, 170-8428
Tel: 0120-60-1036 (Direct)
10:30 a.m. - 5:00 pm. (excluding Saturdays, public holidays, and year-end/New Year holiday period)
Email address: ph-psi-privacy@princehotels.co.jp

Enacted: April 15, 2021