Privacy Policy

In connection with Emma’s recruitment process for new employees, trainees and freelancers, we will collect and process your personal data. This applies both to advertised vacancies for which you apply and where we contact you directly, as well as to personal data collected through the use of Emma’s job portal (the “Job Portal”).

This privacy notice (the “Privacy Notice”) is issued to inform you how EMMA SLEEP GMBH, and its participating corporate entities/ affiliates (each a “Emma Entity”) and together with EMMA SLEEP GMBH the “Emma Group” or merely “Emma” will collect and process personal data about you.

  1. Information concerning the collection of Personal Data
    The Privacy Notice applies to our collection, processing, and utilization of your Personal Data at the beginning of your application process with Emma and throughout the duration thereof. “Personal data” means all information relating to an identified or identifiable natural person whether recorded in a material form or not, which, by itself or when put together with other information, would reasonably and directly reveal the identity of a natural person. “Sensitive personal data” are any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, including the processing of genetic data and biometric data for the purpose of uniquely identifying a natural person, as well as data concerning health, sex life, sexual orientation, or other categories deemed sensitive under applicable local laws.
  2. Data Controller
    The data controller responsible for processing your personal data is the Emma Entity based in the country where the position you applied for is located. The Emma Entity will be stated in the job advertisement if this concerns an advertised vacancy. In the case of an inquiry from Emma, the specific legal entity will be clearly stated in the inquiry. An updated list of the Emma Entities can be accessed at the end of this Privacy Policy.  

    The Job Portal is operated by Emma Sleep GmbH, in order to support the recruitment functions on behalf of the other Emma entities.  

    You can reach the Emma Group data protection officer through the following e-mail address:
    Email:     privacy@emma-sleep.com

  3. Categories of Personal Data processed
    1. Emma may process the following categories of Personal Data which you provide to us, or we collect from you at the beginning and during the course of your job application (the “Categories of Personal Data”). Note that the list of examples for every Category of Personal Data are not exclusive:
      • Name
      • Email address
      • Telephone number
      • Password
      • Country/Region of residence
      • Area of function you would like to be working within
      • Preferred languages
      • Potential jobs applied for and the application(s)
      • Personal information you may choose to contain in your application including Cover letter and CV (e.g. address, photo, birthday, gender, marital status, educational background, work experience and other related experience).
      • Cover letter
      • Additional documents uploaded by you in the application process
      • Personal information about you that you have yourself posted e.g. on LinkedIn and similar websites
      • Answers to tests of skills validation and recruitment questionnaires
      • Financial data: bank account details
      • Information collected as part of the interview process, such as notes taken during your interview, background check information, such as information obtained through reference checks and confirmation of your education and employment history.

    3. Emma recommends that you do not provide such data as e.g. health data, racial religious beliefs, political views or ethnic background, trade union membership and sexual orientation etc. from your application material (sensitive personal data). Emma also asks you to cross out any civil registration number on grade sheets and other places where your civil registration number may be stated as does not need to know this information in the recruitment process. 

      Only to the extent you by law are obligated to share health data or other sensitive personal data as part of the recruitment process (in order to comply with the obligations in the field of employment law), you should include such sensitive personal data in the application. 

  4. Sources from which Emma may obtain your personal data 

    1. Emma may obtain data about you from the following sources: 

      1. From you, when you submit resumes or other information online; 
      2. From social media (where allowed by applicable law); 
      3. From background checks, as applicable.  
      4. From other Emma Entities; 
      5. From external recruitment agencies;  
      6. from job search or professional networking websites (LinkedIn, etc.) where you may have made data about yourself publicly available; 

      7. From previous employers (where allowed by applicable law); 

  5. Purposes for processing the Personal Data

    Management and selection of the relevant Applicant’s profiles for the position offered 

     

    • Organization of the recruitment procedure and, if applicable, organization of job interviews. 

    • Organization of optional tests using innovative technologies for the evaluation of Applicant’s application to a specific position  

    • Validate Applicant’s professional experience with their former employers. 

    • Reimbursement of any expenses related to the recruitment process. 

    Promotion of Applicants' profiles within Emma Group   

    • Contact the Applicant if a position becomes available and corresponds to its previous applications if any and its profile.  

    • Communicate to Applicants the relevant job recommendations adapted to their profiles.  

     

    Evaluate Emma recruitment process 

    • Conduct data analytics regarding the recruitment process (i.e. application, and if applicable job interviews) in order to improve the recruitment process of Emma Group. 

    Local verifications / additional tests to select Applicants 

    • Background checks when required by mandatory local laws governing the Emma Entity. 

    Management of the Job Portal 

    • Management, maintenance and security of the Job Portal and other IT tools relating to recruitment to ensure their correct operation and to ensure the proper conduct of the recruitment process from the Applicants’ preselection to their hiring.  

  6. Legal basis for processing

    1. Emma only collects and uses personal data about you in accordance with applicable laws. We will process your personal data for the purposes mentioned in the table above based on your prior consent, to the extent such consent is mandatory under applicable law. 

      To the extent you are asked to accept this policy, such acceptance will be considered as your consent to process your personal data, only in the countries where such consent is mandatory. In all other countries, clicking on acceptance/agreement buttons will be considered as a mere acknowledgement of this statement. 

      Emma will not use your personal data for purposes that are incompatible with the purposes listed in this privacy policy, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so. 

      The legal basis for administering and processing your application are as follows: 

      • Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available, for which a recruiter may connect with you directly - Emma legitimate interests of ensuring that it recruits the appropriate employees for the roles. 

      • Manage your application and undertake pre-hire and/or onboarding actions - Emma’s legitimate interests of ensuring that it recruits/onboards the appropriate employees for the roles. 

      • Facilitate communication with you - Emma’s legitimate interests of ensuring proper communication within the organization and with you. 

      • Perform administrative functions (e.g. reimburse you for interview-related expenses) - Emma’s legitimate interest of ensuring that it recruits the appropriate employees for the roles. 

      • Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Emma and how to attract and keep top talent, and to assist with the sourcing and screening (but not for final recruitment decisions) when processing high volume of applications - Emma’s legitimate interests of ensuring that it continually improves its recruitment processes. 

      • Record your online interview for review by additional recruiters and hiring managers. Consent and Emma’s legitimate interests of ensuring that it recruits the appropriate employees for current or future roles. 

      • Management of the job portal - Emma’s legitimate interests of ensuring the proper handling of the recruitment process. 

      • Perform any legally required reporting and respond to legal process - Compliance with a legal obligation. 

      • Defend Emma against claims from rejected candidates - legitimate interest of Emma in defending its position before authorities or courts.  

      If you by law are obligated to share health data or other sensitive personal data as part of the recruitment process (in order to comply with the obligations in the field of employment law) the legal basis for the processing of these sensitive personal data will be compliance with obligations stated by law. 

      Furthermore, if – and only if – you choose to share with us your profile for future job vacancies within Emma Group, Emma will be processing your personal data for the Purpose of providing you with global employment opportunities and contacting and corresponding with you regarding your interests in current and/or future employment within Emma based on your voluntary consent that can be withdrawn.  

  7. Recipients or categories of recipients of Personal Data 

    Within Emma, as Emma is part of a wider group (Emma Group), Emma may transfer the applicant data to, or otherwise allow access to such data by, other entities within the Emma Group which may use, transfer and process the data for the purposes set out in the section “Purpose of processing”. 

    Your Personal Data may be transferred across Emma’s affiliates and subsidiaries for evaluation purposes whether your job application may be considered for openings in the other entities within Emma.  

    We may also transfer your data to governmental agencies when required by mandatory local laws governing the Emma Entities. 

     

    Data processors: Where necessary for the processing purposes described in the section “Purpose of processing”, personal data may be shared with one or more third parties, whether affiliated or unaffiliated, to process personal data under appropriate instructions ("data processors"). Examples of data processors:  

    • Information Technology (IT) service providers for IT infrastructure  

    • Cloud providers  

    • Recruitment and applicant screening solutions providers  

    • Job Portal and Job Portal management service providers  

    • Consultants for job application and performance evaluations 

    Some of Emma Group companies and suppliers are based outside Europe or have servers or group companies located outside Europe. In such cases, we will ensure a valid transfer mechanism in place, namely adequacy decisions made by the EU Commission, Binding Corporate Rules or the EU and UK Standard Contractual Clauses. In addition, we will implement additional safeguards to ensure that your rights and freedoms as a European citizen are adequately protected also in the case of such transfers of data outside Europe or the UK. You may find a copy of the EU and UK Standard Contractual Clauses we use by clicking

    here. 
     

    We may revise or update our transfer mechanisms to adhere to changes in data protection law or the requirements of the European Commission; if we do so, we shall update this Privacy Policy accordingly. 

    To the extent your consent is required in your country to transfer your personal data from your country to another country or to a third party, your agreement with our privacy policy is considered as your consent to transfer your personal data to such country and/or third party. 

  8. How we protect your Personal Data 

    Emma fully recognizes the value of your Personal Data. Appropriately, we strive to maintain the confidentiality, integrity, and availability of your Personal Data by employing reasonable physical, technical, and operational safeguards and security control measures. We also train our employees to properly handle your Personal Data and are obligated to maintain a duty of confidentiality. Further, we do not knowingly collect Personal Data of individuals who are considered minors (e.g., below 18 years old) or those who cannot validly give consent. 

  9. Storage and retention of your Personal Data 

    Emma may collect, store, process, disseminate or use your Personal Data in a manner that causes it to be transferred or accessed from computer systems owned or operated by or on behalf of Emma (or a vendor of Emma). Your Personal Data are stored in Emma’s cloud which is hosted in servers located in the European Union except when local requirements of the country you are applying to have data localization requirements or prohibit the transfer of personal data.  

    Your Personal Data will be retained in accordance with local legal and regulatory requirements applicable to the country to which you are applying, if any, and subject to Emma's data retention obligations. If the retention period is not defined by local laws and regulations, Emma generally may keep your Personal Data up to six (6) months after closing of the job opening to which you applied for, if your application is rejected or you are not offered employment.   

    If you are offered and accept a position at Emma, relevant parts of your application material (primarily application, CV, any exam certificates and diplomas as well as, if applicable, health data of relevance to your work capacity) may be transferred to your staff folder. Other application material will be erased. Your staff folder will be erased, according to mandatory retention periods foreseen in the applicable local law, and no later than five years after you have left your position at Emma. 

    Sometimes we may ask if you want us to keep your personal data for a longer period, for example if you do not qualify for a position but we would like to be able to keep you in our database for other potential future vacancies within the Emma Group. You may at any time withdraw any consent to storage and processing of your personal data. 

    To the extent you have applied for positions with Emma in more than one country, we will hold your personal data for the retention periods required by local law.     

    Emma also retains your personal data where this is advisable to safeguard or improve Emma’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations). 

    Absent any restrictions, please be informed that Emma may delete your profile on the Job Portal or some or all of the Personal Data that we have about you (including your CV/resume) at any time for any reason and without notice by following generally accepted industry standards. Therefore, please retain your own copy of the Personal Data which you provided to us. 

  10. Your rights as a data subject 

    As a data subject, you are afforded several rights and freedoms under applicable data protection laws and regulations. To exercise such rights, please contact our Data Protection Officer at privacy@emma-sleep.com. In order to ensure that we do not share personal data with unauthorized third parties, we will request that you confirm your identity before we respond to your request. Provided that we have confirmed your identity, we will respond as soon as possible and normally within 30 days, unless applicable local laws require otherwise. If we are not able to respond within 30 days, we will notify you of the delay and the reason for it in due course and prior to the 30-day deadline. Below is an overview of your rights.  

    Your data subject rights vary depending on the laws of the country in which the Emma entity you are applying to is located. Within the limitations set out in applicable law, you have the following privacy rights: 

    • Right to information: you have the right to obtain further information on our use of your personal data. 

    • Right of access: You may request access to a copy of the personal data we process about you. Please note that there are some exceptions to this right, for example if the access infringes on the rights of others (for example it reveals personal information about a third party) or if it pertains to business secrets. If we make any exceptions to your right of access, we will inform you of this specifically 

    • Right to rectification: It is important for us to ensure that we only process personal data which is correct and up to date. If you see that any of the personal data we process is incorrect, then you have the right to demand rectification.  

    • Right to data portability: You may obtain an electronic copy of the personal data you have provided to us in a digital format either directly to you or to a third party designated by you 

    • Right to be forgotten: We only store personal data for the time needed to fulfill the purposes it was collected for. If you are of the opinion that we are storing information that should have been deleted, you may request that we delete such personal data. Please be advised however, that legal obligations such as tax reporting and book keeping may result in us being obligated to not delete the personal data until the statutory retention period has expired.  

    • Right to objection: You may object to our processing of your personal data if your particular situation so requires. Please note that this may lead to us not being able to continue processing of your job application.  

    • Right to restriction of processing: You have the right to request that we restrict the processing of your personal data for example if you are of the view that we are processing your data illegally or if you do not want us to delete data that are due for deletion 

    • Automated decisions and profiling: We do not use automated decisions pertaining to you for recruitment purposes. For the purpose of sending you open positions, we use segmentation techniques and perform analysis in order to optimize our recruitment efforts and to tailor such communications to our candidates’ preferences and needs. Such analysis may influence the job openings you will receive, but are not applied in a manner which may result in legal or similar significant effects for you. 

    • Right to withdraw consent at any time: If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal of consent will not affect the lawfulness of the processing of data that precedes the withdrawal of your consent. 

    • Right to file a complaint before a data protection supervisory authority: if you have any complaints about Emma processing of your personal data, you always have the right to lodge a complaint with the relevant supervisory authority. If you are in the EEA you may consult the relevant supervisory authorities

      here. 
       

     You can reach us to exercise your right through the following e-mail privacy@emma-sleep.com. 

  11. Changing the Privacy Notice  

    Emma reserves the right to modify or amend the Privacy Notice from time to time to keep up with any changes in relevant laws and regulations applicable to Emma or to reflect how we collect, use, protect, store, share or dispose of your Personal Data. If you do not agree to the changes, please contact our data protection officer to have your Personal Data removed from the Job Portal and our databases. You can tell when we last updated the Privacy Notice by checking the document control information at the bottom. 

  12. Cookie Policy

    1. Cookies

      1.  In addition to the categories of Personal Data mentioned above, we use cookies to make the experience of using the Job Portal as user-friendly as possible and to allow you to make use of certain functions. Cookies are little text files that are saved on your browser’s delegated hard drive, through which certain information flows back to the entity who sets the cookie (Emma in this case). Cookies are used to improve the user experience and effectiveness of our website.

      2. This website uses the following types of cookies:

        1. Transient Cookies
          Transient cookies are automatically deleted when you close your browser. These are mostly session cookies, which save a so-called “session-ID”, which allows for the assigning of different queries within your browser during a particular session. This can be used to identify your device when one repeatedly visits a website during a session. These cookies are deleted once you log out or the browser window is closed.  
        2. Persistent Cookies
          Persistent cookies enable the website to remember your information and settings on your next visit. This gives you faster and more convenient access to the website, as you do not have to change your language settings again, for example. How long the cookie remains on your device depends on the duration or expiration date of the respective cookie and your browser settings. These cookies are automatically deleted after a set period of time which can differ from cookie to cookie. Persistent cookies can be deleted via the security settings in your browser at any time.
      3. Depending on the kind of cookie, we use cookies either on the basis of our legitimate interests (technically necessary cookies) or on the basis of your consent (optional cookies), according to your selection of the cookie banner displayed when you access the Job Portal. You can also configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. Note that this may result in a functional limitation of the Job Portal.

        1. Below is a list of the cookies used by the Job Portal: 

         

        Cookie 

        Domain Type 

        Description 

        Duration 

        _ga 

        Lever Analytics 

        This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data, and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors. 

        2 years 

        _gid 

        Lever Analytics 

        The cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected includes the number of visitors, the source where they have come from, and the pages visited in an anonymous form. 

        1 day 

        ajs_user_id 

        Lever Analytics 

        The cookie is set by Segment.io and is used to analyze how you use the website. 

        1 year 

        ajs_anonymous_id 

        Lever Analytics 

        This cookie is set by Segment.io to check the number of new and returning visitors to the website. 

        1 year 

        _gat 

        Lever Performance 

        This cookie is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic rates. 

        1 minute 

List of Hiring Emma Entities 

  • Emma Sleep GmbH 

  • Emma Sleep Portugal Unipessoal LDA 

  • Bettzeit Southeast Asia Inc. 

  • Bettzeit (Shanghai) Co. Ltd. 

  • Emma Sleep Mexico S. de R.L. de C.V. 

  • Emma Services GmbH 

  • Emma Sleep S.r.l. 

  • Emma Sleep NL B.V. 

  • Emma Sleep Italy Srl 

  • Emma Sleep UK Limited 

  • Emma Sleep Korea Limited 

  • Emma Sleep Japan G.K.  

  • Emma Sleep India Private Limited 

  • Emma Sleep Hong Kong Limited 

  • Emma Sleep France SAS