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PRIVACY POLICY

Coupa is committed to protecting and respecting your privacy. In this privacy
policy ("Privacy Policy"), we explain how Coupa collects, uses, discloses and
protects the Personal Information you submit to us, including, for example, when
accessing and using Coupa websites or applying for job offerings.

Our Privacy Policy has been drafted to comply with applicable data privacy laws,
in particular, the GDPR and the CCPA. If the GDPR or another Applicable Data
Privacy Law does not apply to you, not all terms of this Privacy Policy may be
relevant to you.

As used in this Privacy Policy,

 * “Applicable Data Privacy Laws” may include (i) EU General Data Protection
   Regulation (EU) 2016/679 (“GDPR”), (ii) other data protection laws applicable
   in member states of the EEA, (iii) the UK Data Protection Act 2018, (iv) any
   U.S. privacy, security, breach notification, or other data protection laws
   applicable to Personal Information, including but not limited to the
   California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq (“CCPA”).
 * “Coupa”, "we," "our" and "us" means Coupa Software Inc. and its affiliates.
 * “Coupa Platform” means any software and hardware that enables Coupa to
   provide our customers and their business partners with access to and use of
   the Coupa services, including the Coupa Supplier Portal.
 * “Controller” or “Processor” (as applicable) for the purposes of the GDPR,
   other data protection laws applicable in member states of the European Union
   and other provisions related to data protection is Coupa Software Inc., 1855
   S. Grant Street, San Mateo, CA 94402, USA.
 * “Personal Information” generally has the same meaning as personal data or
   personal identifiable information (PII). Personal Information is defined in
   the data privacy laws applicable in your country. It includes any information
   relating to an identified or identifiable natural person. This means any
   individual who can be identified directly or indirectly by reference to an
   identifier such as name, identification number, location data, online
   identifiers (for example, IP addresses – if they can be used to identify you)
   or to one or more factors specific to the physical, physiological, genetic,
   mental, economic, cultural or social identity of that natural person. Put
   simply, this includes data which either by itself or with other data held by
   us or available to us, can be used to identify you.

Coupa's role

Coupa is acting in the capacity of Controller when collecting and processing
personal data on its own behalf and for its own purposes. This means situations
in which Coupa determines the purposes and the means of such processing at its
own discretion.

For certain services, Coupa has been retained by our customers to process
personal data as a Processor. In such cases, Coupa shall process your personal
data on behalf of and based on the specific instructions given by our customer
as the Controller. The subject-matter and duration of the processing, the nature
and purposes of the processing, the type of personal data and categories of data
subjects, together with the rights and obligations of the parties with respect
to such processing will be covered by a data processing agreement (or equivalent
terms) agreed between Coupa and our customer.

When a Coupa customer uploads personal data (typically contact information) of
their business partners (suppliers, prospective suppliers or other) to the Coupa
Platform, then the Coupa customer is the Controller of such personal data. If a
business partner creates a supplier account on the Coupa Supplier Portal, then
Coupa is the Controller of any personal data provided.

Coupa is committed to the following key principles:

Principle 1. We limit how, and with whom, we share your Personal Information.

Coupa will only share your Personal Information with others for the following
purposes:

 * at your request;
 * to process or service a transaction or product authorized or requested by
   you; this may include sharing within the Coupa group of entities;
 * when required by law to disclose such information to appropriate authorities;
 * to companies that assist us in marketing, placement and servicing our
   products and services; for example, in order to support our information
   technology or to handle mailings on our behalf;
 * to our event sponsors and partners in connection with event registrations and
   marketing events, which may include sharing Personal Information with our
   sponsors and partners for their own commercial purposes if permitted by
   applicable law without your consent (See “Marketing Information” section
   herein);
 * to companies that assist us in our job recruiting efforts or evaluating job
   applications; and
 * to our professional advisers.

We do not sell Personal Information for money but some third-party cookies on
our website or some of our relationships with event sponsors and partners may be
considered a "sale" or “sharing” as defined under the CCPA.

Principle 2. We collect only the information necessary to deliver the products
and services you request.

Coupa collects only the Personal Information necessary to serve your needs, to
protect against fraud, to fulfill legal and regulatory requirements, and for the
other purposes set forth below:

Personal Information Purpose Legal Basis Information we receive from you when
(i) you visit www.coupa.com and other Coupa websites and (ii) any other
information you subsequently provide to us orally, in writing or through the
internet: this may include your full name, postal address, e-mail address,
employer/business and professional information, job titles, telephone and fax
numbers, demographic information, IP address The Personal Information is used in
providing the website and answering requests from you (e.g. if you choose to
register to receive information about our products and services or if you
enquire about these, we will use your Personal Information in order to respond).
The processing is necessary for the performance of a contract to which you are
party or in order to take steps at the request of you prior to entering into a
contract. Processing is necessary for the purposes of our legitimate interests,
i.e. providing a website for information and use. Your consent (if such consent
is required by law). Name, address, e-mail address and other information about
your transactions and communications with us. The Personal Information is used
to process or service a transaction or product authorized or requested by you.
The processing is necessary for the performance of a contract to which you are
party or in order to take steps at the request of you prior to entering into a
contract. Name, address, e-mail address and other contact information To
periodically contact you to inform you of new products, events and/or services
we provide or that we consider to be of interest to you, and to provide to our
event sponsors and business partners which enables them to inform you of
products or services they provide that they consider to be of interest to you.
Your consent (if such consent is required by law). IP address and other
information submitted by your browser To diagnose any problems with our server
and administer our website and in line with our Cookie Policy. Processing is
necessary for the purposes of our legitimate interests, i.e. providing a website
for information and use. Your consent (if such consent is required by law).
Application data, including your name, address, email, phone number, CV/resume,
birthdate, education and job history, candidate job titles, any personal
information you elect to provide via cover letters or links to third party sites
(e.g., LinkedIn, Twitter, GitHub, Portfolio, etc.), gender, race, disability or
veteran status if you elect to share that information during the job application
process, photograph, travel-related information such as frequent flyer numbers
(if applicable), and visa-related personal information (if applicable), such as
passport numbers, proof of citizenship, and birth certificates. Processing is
required to enable us to administer the recruiting process, including the set-up
of an electronic job applicant HR file, managing your application, organizing
interviews. We may retain your Personal Information following your unsuccessful
application so that we may contact you in case of future job vacancies. Your
data may also be shared with other Coupa group companies to consider your
application for other job openings. Primarily, the processing is necessary to
take steps for entering into a contract with you. We also have a legitimate
interest to (i) store your data for a period of up to 3 years (unless local
legal or regulatory requirements prescribe a shorter period) following the
conclusion of an unsuccessful application and/or (ii) to share it with the Coupa
group of entities and/or (iii) to retain and use your data as far as necessary
for the establishment, exercise or defence of legal claims. All of the above For
compliance with legal and regulatory requirements and corporate governance
obligations. Processing is necessary for compliance with legal obligations to
which we are subject.

Personal Information

Information we receive from you when (i) you visit www.coupa.com and other Coupa
websites and (ii) any other information you subsequently provide to us orally,
in writing or through the internet: this may include your full name, postal
address, e-mail address, employer/business and professional information, job
titles, telephone and fax numbers, demographic information, IP address

Purpose

The Personal Information is used in providing the website and answering requests
from you (e.g. if you choose to register to receive information about our
products and services or if you enquire about these, we will use your Personal
Information in order to respond).

Legal Basis

The processing is necessary for the performance of a contract to which you are
party or in order to take steps at the request of you prior to entering into a
contract. Processing is necessary for the purposes of our legitimate interests,
i.e. providing a website for information and use. Your consent (if such consent
is required by law).

Personal Information

Name, address, e-mail address and other information about your transactions and
communications with us.

Purpose

The Personal Information is used to process or service a transaction or product
authorized or requested by you.

Legal Basis

The processing is necessary for the performance of a contract to which you are
party or in order to take steps at the request of you prior to entering into a
contract.

Personal Information

Name, address, e-mail address and other contact information

Purpose

To periodically contact you to inform you of new products, events and/or
services we provide or that we consider to be of interest to you, and to provide
to our event sponsors and business partners which enables them to inform you of
products or services they provide that they consider to be of interest to you.

Legal Basis

Your consent (if such consent is required by law).

Personal Information

IP address and other information submitted by your browser

Purpose

To diagnose any problems with our server and administer our website and in line
with our Cookie Policy.

Legal Basis

Processing is necessary for the purposes of our legitimate interests, i.e.
providing a website for information and use. Your consent (if such consent is
required by law).

Personal Information

Application data, including your name, address, email, phone number, CV/resume,
birthdate, education and job history, candidate job titles, any personal
information you elect to provide via cover letters or links to third party sites
(e.g., LinkedIn, Twitter, GitHub, Portfolio, etc.), gender, race, disability or
veteran status if you elect to share that information during the job application
process, photograph, travel-related information such as frequent flyer numbers
(if applicable), and visa-related personal information (if applicable), such as
passport numbers, proof of citizenship, and birth certificates.

Purpose

Processing is required to enable us to administer the recruiting process,
including the set-up of an electronic job applicant HR file, managing your
application, organizing interviews. We may retain your Personal Information
following your unsuccessful application so that we may contact you in case of
future job vacancies. Your data may also be shared with other Coupa group
companies to consider your application for other job openings.

Legal Basis

Primarily, the processing is necessary to take steps for entering into a
contract with you. We also have a legitimate interest to (i) store your data for
a period of up to 3 years (unless local legal or regulatory requirements
prescribe a shorter period) following the conclusion of an unsuccessful
application and/or (ii) to share it with the Coupa group of entities and/or
(iii) to retain and use your data as far as necessary for the establishment,
exercise or defence of legal claims.

Personal Information

All of the above

Purpose

For compliance with legal and regulatory requirements and corporate governance
obligations.

Legal Basis

Processing is necessary for compliance with legal obligations to which we are
subject.

Where you wish to provide us with Personal Information about another person,
including colleagues or the persons you act on behalf of, you must ensure that
you have their prior permission to do this. You must also share with them a copy
of this Privacy Policy as well as any other relevant privacy statements (see
above) before you ask them for this permission.

We collect Personal Information for the purposes described above when you visit
www.coupa.com and other Coupa websites and from public sources, such as
recruiting and business portals (e.g.  www.linkedin.com,
http://www.zoominfo.com/, https://clearbit.com/, http://www.echobot.de/. We may
collect Personal Information from public registers and authorities (e.g. the
UK’s Companies House, tax authorities, the Securities and Exchange Commission)
to verify the information provided and to increase its quality for our products
and services.

Principle 3. We establish safeguards to help ensure the security and
confidentiality of your information.

Coupa restricts access to your information to our employees who need it to do
their job. Employees with access to your information are required to strictly
maintain the confidentiality of such information.

Coupa maintains physical, electronic and procedural safeguards that comply with
Industry standards to protect your company’s information. We routinely test our
information systems and websites to help ensure that unauthorized access does
not occur.

Principle 4. We keep your Personal Information for as long as it is necessary to
do so to fulfil the purposes for which it was collected as described above.

The criteria we use to determine data retention periods for Personal Information
includes the following: (i) Retention in case of queries: We will retain it for
a reasonable period after the relationship between us has ceased in case of
queries from you; (ii) Retention in case of claims: We will retain it for the
period in which you might legally bring claims against us; (iii) Retention in
accordance with legal and regulatory requirements: We will consider whether we
need to retain it after the period described in (ii) because of a legal or
regulatory requirement, e.g. to comply with tax or fiscal duties; (iv) Retention
in case of job applications: If you applied for a job offering with Coupa and
have not been successful, your application data will be retained in our talent
pool for a limited period as defined in Principle 2.

Give Us Your Feedback

Our goal is to protect your privacy. To comment or help us improve, please
contact us via email (see email contacts below) or telephone (+1.650.931.3200).
You may also contact us via written letter at Coupa’s address listed above. We
may ask you to provide a copy of your proof of identity.

Email contacts

If you: Contact: Are a job applicant, employee or alumni privacy.hr@coupa.com
Are a prospect, customer, partner or other contact receiving Coupa product and
services information privacy.marketing@coupa.com Have general questions about
data privacy at Coupa privacy@coupa.com Wish to contact the Coupa Data
Protection Officer directly dpo@coupa.com Are a supplier on the Coupa Platform
supplier@coupa.com

If you:

Are a job pplicant, employee or alumni:

Contact:

privacy.hr@coupa.com

If you:

Are a prospect, customer, partner or other contact receiving Coupa product and
services information:

Contact:

privacy.marketing@coupa.com

If you:

Have general questions about data privacy at Coupa:

Contact:

privacy@coupa.com

If you:

Wish to contact the Coupa Data Protection Officer directly:

Contact:

dpo@coupa.com

If you:

Are a supplier on the Coupa Platform:

Contact:

supplier@coupa.com

If you consider that we are in breach of our obligations under data protection
laws, you may lodge a complaint with the competent Data Protection Authority,
which may be the supervisory authority in your country of residence or place of
work, of an alleged violation of data protection laws.

Changes to this Privacy Policy

This privacy policy may be modified from time to time to comply with applicable
laws or to conform to our current business practices. We will post any changes
to this on our website and, if required by applicable law, will endeavor to
notify you via your contact email. We encourage you to revisit the Privacy
Policy that is posted on our web site from time to time to check for updates.

ADDITIONAL INFORMATION WE WANT YOU TO KNOW:

Transfers outside the EU/EEA. We also transfer the Personal Information we
process to countries outside the European Economic Area (”EEA”) (e.g., when one
of our service providers or equipment is based outside the EEA, such as for
hosting your Personal Information). We have put in place adequate safeguards
with respect to the protection of your privacy, fundamental rights and freedoms,
and the exercise of your rights, e.g. we establish an adequate level of data
protection, usually through EU Standard Contractual Clauses based on the EU
commission’s model clauses.

Provision of Personal Information / Automated decision making. Please note that
the Personal Information we collect from you is necessary to providing the
services and the website to you. Failure to provide such data may not enable us
to provide our services to you or make our website accessible. We do not use
automatic decision-making or profiling of individuals.

Your Rights. You may have various rights under data privacy laws in your country
or state. These may include (where required by law): the right to request access
(right to know) to the Personal Information we hold about you; the right to
rectification (right to correct) including to require us to correct inaccurate
Personal Information; the right to request restriction of processing concerning
you or to object to processing of your Personal Information, the right to
request the erasure (right to delete) of your Personal Information where it is
no longer necessary for us to retain it; the right to data portability including
to obtain Personal Information in a commonly used machine readable format in
certain circumstances such as where our processing of it is based on a consent;
the right to opt out of sales or sharing of your Personal Information; the right
to object to automated decision making including profiling (if any) that has a
legal or significant effect on you as an individual; and the right to withdraw
your consent to any processing for which you have previously given that consent.

Marketing Information. With your consent (if obtaining such consent is required
by law), we will keep your name, address and contact details (including
telephone numbers and email addresses) in our databases and may from time to
time use that information to make you aware of our related products and services
as well as updates on developments in our industry sector generally which may be
of interest to you. We may contact you in writing, by telephone or email for
this. If permitted by applicable law, we may share such information with our
event sponsors and/or partners for their own commercial purposes without your
consent. If at any time you decide that you do not want your contact details
used or shared for these purposes, where applicable, you may object or revoke
your consent for receiving marketing communications by following the
instructions in the relevant marketing communication (e.g., clicking on the
“Unsubscribe” button), by contacting us (see “Give Us Your Feedback” above), or,
if applicable to the scenario, by visiting the preference center at
https://www.coupa.com/preference-center.html.

Security Statement. We take reasonable precautions to protect your information.
In particular, we implemented appropriate technical and organisational measures
designed to ensure a level of security appropriate to the risk, including as
appropriate: (a) pseudonymisation (such as where data is separated from direct
identifiers so that linkage to an identity is not possible without additional
information that is held separately) and encryption, (b) protecting the ongoing
confidentiality, integrity, availability and resilience of systems and services
used to process your Personal Information, (c) providing the ability to restore
the availability and access to Personal Information in a timely manner in the
event of a physical or technical incident; and (d) maintaining a process for
regularly testing, assessing and evaluating the effectiveness of technical and
organizational security measures. When you submit information to us through our
website, your information is protected both online and offline. All data
transferred to/from the Coupa internal network, from/to an external entity, is
encrypted to industry standards (256-bit encryption). Please keep in mind that
messages you send to us by Internet e-mail may not be secure. We maintain
appropriate physical, electronic and procedural safeguards to ensure the
security, integrity and privacy of your personal information within our company.
Only those employees who may require your information to perform a specific job
are granted access to your organization’s identifiable information. Furthermore,
all employees are kept up to date on our security and privacy practices.

Our Use of Cookies and Analytic Tools. Coupa uses “cookies” and analytic tools
as further described in our Cookie Policy.

Third Party Websites. Our websites and mobile apps may contain links to
third-party websites. If you follow these links, you will exit our websites or
mobile apps. This privacy policy does not apply to websites of third parties.
Coupa cannot accept liability for the use of your Personal Information by these
third parties. Your use of these websites is at your own risk. For more
information on how these third parties treat your Personal Information, please
check their privacy policy (if available).


BREADCRUMB

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