We are committed to continuously improving the sleep experience of individuals across the globe in a manner that respects, perseveres, and protects privacy and personal information. The protection of your personal information is important to us, and we want you to feel safe when accessing our website and participating in our surveys, questionnaires, and/or contests.

This Privacy Policy (“Policy”) shall inform you about the collection, processing, and utilization of your personal information when you decide to participate in the Emma Pillow Giveaway hosted by Emma Sleep Japan G.K. (“Emma”, “we” or “us”).

Should you have any concerns or inquiries about how we are handling your personal information, you may reach out to our data protection officer by contacting us through privacy@emma-sleep.com or by sending us a letter addressed to “Data Protection Officer”.

1. Identity and contact details of the controller

Controller as per the applicable data protection law is:

Emma Sleep Japan G.K.

C/O Business Airport Kyobashi, FPG links Kyobashi, 2-7-8, Chuo-ku, Tokyo 1040031.

2. Collection and processing of persoal information

We collect and process your personal information when you access and participate in the Emma Pillow Giveaway and its corresponding survey / questionnaire.

When accessing the website, your data which your device transmits to our server is automatically saved. In order to fulfill technical requirements for you to use the survey and provide for security purposes, the following data may be saved: IP address,date and time of your visit, time zone different to Greenwich Mean Time (GMT), content of query (specific site visited), access status / HTTP status code, amount of transferred data, operating system, device and its user interface.

The types of data mentioned above get processed for our legitimate interests and to ensure you a smooth and comfortable use of the website and to evaluate system security and stability, as well as for other administrative purposes. We will process this data for security reasons and for protection against intrusions under the legal basis of our legitimate interest. When you visit and use the website, the data mentioned above is automatically recorded without your intervention and stored until it is automatically deleted. If you don’t want the above data to be collected, we will be unable to allow you access to the website without such data.

When you access, engage, or respond to our surveys, quizzes, or questionnaires (hosted via Google Forms), we may ask you to provide certain personal information, such as your name, email address, age, address, and phone number. This personal information will be used to process your entry and to contact you in case you win the giveaway. Furthermore, your email address will be processed for marketing purposes if you give us your consent to receive marketing from Emma.

When you choose to give us your consent to receive marketing from Emma, we will send you newsletters by email containing promotional information about our products, offers, editorial content, and articles about our company. To subscribe to the newsletter, it is sufficient to enter your email address and give your consent to receive marketing. The provision of further personal information is voluntary and will be used to address you personally. After you give your consent, we will save your email address for the purpose of sending the newsletter. The purpose of this is to be able to prove your subscription to our newsletters, and if necessary, clarify any possible misuse of your personal information. To stop receiving the newsletter, you can withdraw your consent at any time, by clicking the unsubscribe link in every newsletter or by sending a data subject request to privacy@emma-sleep.com.

When you access our contact form or if you contact us (e.g. via email, etc.), we may ask you to provide certain personal information such as your name and email address. The information you provide will be processed for the purpose of processing the request and in the event that follow-up questions arise. The contact form is an additional service from us to enable you to contact us quickly and easily if you have any queries about our products and services. The personal information collected by us in this context will be deleted when the inquiry or issue associated with the contact has been completely clarified and it is not to be expected that the specific contact will become relevant again in the future, unless there are statutory retention requirements to the contrary.

Technologies such as pixels and cookies are used by us and our service providers to make the website experience as user-friendly as possible and to allow you to make use of certain functions. Depending on the kind of tool or service, we use these on the legal basis of our legitimate interests or on the basis of your consent.

These technologies are used in analyzing website trends, usage, and demographics among others. Further information about the personal information we may collect from you varies depending on the service provider we use. The details for each service provider are listed below in section 5.

3. Data storage and retention

We retain your personal information for no longer than is necessary for the purposes stated in this Privacy Policy. In the event we do not need your information in order to provide the service to you, we will retain it only for so long as we have a legitimate business purpose in keeping such data under applicable laws and regulations.

We may collect, store, process, disseminate or use your personal information in a manner that causes it to be transferred to accessed from computer systems owned or operated by or on behalf of us. Your personal information may be transferred and stored in the European Economic Area (“EEA”) or United States of America through our service providers.

Your personal information will be retained in accordance with local legal and regulatory requirements applicable to the country you are using the website from, and subject to our data retention obligations. We keep your personal information for the period of the user relationship with you or for the legally required period after termination of such relationship in order to defend our legal claims, to protect and enforce our rights, or to comply with laws and regulations.

4. Your rights as a data subject

Under the applicable data protection law, you have the following rights with respect to the personal information concerning you:

• Right to access by the data subject

• Right to erasure

• Right to object

• Right to withdraw consent

If you feel that we have not responded in an appropriate manner to your complaints or you have further concerns, you have the right tocomplain to the relevant data protection authority. Depending on your location, the responsible authority for us is the Personal Information Protection Commission.

For inquiries regarding your rights as a data subject, you can direct to us through privacy@emma-sleep.com or by post to the Controller’s postal address.

5.Transfers and categories of recipients of personal information

We share your personal information to our service providers to help us ensure the functionality of the website. We may also share information with our analytics service providers to help us for the optimization of the website. Within the scope of our activities and services, it may become necessary for us to disclose the personal information stored about you to natural persons, legal entities, or public authorities. We may share your personal information as described in this Privacy Policy to comply with our legal obligations and to protect and defend our rights.

To provide a smooth experience for you, we may disclose your personal information from time to time with our contracted service providers (“processor” or “processors”). We execute contracts with our service providers, to ensure that they may only process your personal information in a way that we have explicitly instructed them to do so. Furthermore, we ensure that our service providers take the necessary technical and organizational measures to process your data securely and store your personal information only for as long as necessary.

External service providers who may receive personal information generally fall into the following categories of recipients:

• Emma Sleep GmbH's subsidaries and affiliates
• IT service providers to maintain our IT infrastructure
• Cloud providers
• Service providers for the optimization of the website services and functions

If your personal information is processed and transferred to third countries outside Japan, we will ensure that your personal information is processed in accordance with your country’s data protection level. In the absence of an adequacy decision, we only transfer data to service providers from third countries that offer suitable guarantees and put the appropriate data processing agreements and standard contractual clauses in place.

To be able to run the website and provide you a seamless experience, we engaged the following service providers listed below. When you choose to use the website, we may transfer your personal information to our service providers in the EEA and/or United States of America, where these services are
hosted.

Google Forms. We use Google Forms, which is provided by Google LLC, which is based in1600 Amphitheatre Parkway Mountain View, California 94043 USA, in order to host our online surveys, quizzes, or questionnaires. The data collected for this purpose are your email address, name, and other responses to the questionnaire. We process the data provided in this form on the basis of legitimate interest in order to process your entry to the giveaway. The data will be deleted as soon as it is no longer
needed for the stated processing purposes. You can reach their data protection officer through https://support.google.com/policies/answer/9581826?p=privpol_privts&hl=en&visit_id=638556555956320822-2321358657&rd=1.

6. Third Party Terms and Conditions

Our Privacy Policy does not apply to products and services offered by a third party. Our products and services may include third parties’ products, services, and links to third parties’ websites. When you use such services, they may collect your personal information. As such, we recommend reading the processors’ privacy policies linked above.

7. Updates to this privacy policy

We keep this Privacy Policy under regular review and may update this Privacy Policy from time to time to reflect the changes in our services. We encourage you to read and/or review this Privacy Policy periodically for the latest updates on our privacy practices.