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SAP PRIVACY STATEMENT






EFFECTIVE DATE: OCTOBER 3, 2022

To view the previous version of this Privacy Statement, click here.


SAP PRIVACY STATEMENT

Protecting the individual's privacy is crucial to the future of business. We
have created this privacy statement to demonstrate our firm commitment to the
individual’s right to data protection and privacy. It outlines how we handle
information that can be used to directly or indirectly identify an individual
(personal data). 


WHO DO WE MEAN WHEN WE SAY SAP IN THIS PRIVACY STATEMENT?

This privacy statement applies to the collection and processing of personal
data:


 * during the central operation of this website and other globally operated SAP
   business activity by
   * SAP SE, Dietmar-Hopp-Allee 16 Walldorf 69190, Germany if you are in a
     member state of the EU or the EWR or in any of the countries of Andorra,
     Faroe Islands, Guernsey, Isle of Man, Jersey, Switzerland, or the United
     Kingdom or by
   * SAP America Inc., 3809 West Chester Pike, Suite 200, Newtown Square, PA
     19073, USA if you are in any other country, or
   * a specific SAP group entity as may be stated in the Additional Country and
     Regional Specific Provisions at the end of this privacy statement.
 * in the context of a pre-contractual or contractual business relationship with
   you or your employer by a local SAP group entity
 * in the context of a registration form when a specific SAP group entity is
   directly collecting personal data for the purpose of registering to a service
   or event and is therefore presented as the relevant controller on this
   registration page or website by referencing to this privacy statement.

SAP SE, SAP America, Inc., and each relevant SAP group entity are, depending on
the given case, hereinafter referred to as “SAP”.

 

This privacy statement does not apply to SAP internet-pages or web-services
which present their own Privacy Statement.

FOR WHAT PURPOSES DOES SAP PROCESS YOUR PERSONAL DATA?

When conducting business and operating our various web presences and other
communication channels, SAP processes personal data of the people it interacts
with, including customers, partners, suppliers, vendors, candidates, and any
other people with whom we interact.

In any of these cases, SAP may process personal data for one or more of the
following business purposes:

 

To pursue business relationships with customers, partners, and others

SAP processes personal data to pursue its business relationships with customers,
partners, and other users to fulfill pre-contractual and contractual business
relations. This may include satisfying requests, processing orders, delivering
an ordered product or service, or engaging in any other relevant action to
establish, fulfill and maintain our business relationships.

 

Products and services may include any of SAP’s on-prem and cloud software
products, web services, apps, online-forums, webinars and events, non-marketing
related newsletters, white papers, tutorials, trainings, as well as other
offerings like contests or sweepstakes. When you purchase or intend to purchase
products or services from SAP on behalf of a corporate customer or are otherwise
associated as contact person for the business relationship between SAP and a
corporate customer or partner (a “Customer Contact”), SAP will use your personal
data for this purpose. More specifically, SAP may use your personal data to
confirm your opening of an account, manage the contract execution, send you
disclosures as may be required by law, notice of payments, and other information
about our products and services. SAP may respond to related inquiries, provide
you with necessary support and process your feedback.

 

In the context of your or your employers use of our products or services, SAP
may communicate with you by post, email, live chat, contact forms, phone or any
other medium to resolve your, a user’s, or a customer’s question or complaint or
to investigate suspicious transactions. In case of telephone calls or chat
sessions, SAP may record such calls or chat sessions to improve the quality of
SAP’s services after informing you accordingly during that call and, subject to
applicable law, receiving your prior consent before the recording begins.

 

Customer Satisfaction - Within an existing business relationship between you or
your employer and SAP, SAP processes your personal data to help us understand
how satisfied you are with the functionality and quality of our products and
services, to provide you with relevant information on our latest product
announcements, software updates or upgrades, events, special offers, and other
information about SAP’s software and services that is relevant and useful to
you.

 

To develop products and services

To the extent permitted by applicable law, SAP may process your personal data
for internal research, technological demonstration and development, and to help
SAP create, develop, operate, deliver, improve, upgrade or enhance SAP products
and services. SAP may process personal data to create anonymized data sets which
may then be used to improve SAP’s products and services.

 

To ensure compliance with laws and regulations

SAP processes personal data to comply with statutory obligations.

 

SAP processes your personal data for the purpose of ensuring an adequate level
of technical and organizational security of SAP's products, services, online
events, facilities, and premises. For this, SAP will take the measures necessary
to verify or maintain the quality and safety of a product or service which is
owned, manufactured by or for, or controlled by SAP. This may comprise the use
of personal data for sufficient identification and authorization of designated
users, internal quality control through auditing, analysis, and research,
debugging to identify and repair errors that impair existing or intended
functionality, account and network security, replication for loss prevention,
detecting security incidents, protection against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for such kind
of activity. We may further process your name, likeness, and other contact or
compliance related data when you visit a local SAP affiliate or lab in the
context of access management and video surveillance to protect the security and
safety of our locations and assets.

 

SAP and its products, technologies, and services are subject to the export laws
of various countries including, without limitation, those of the European Union
and its member states, and of the United States of America. Applicable export
laws, trade sanctions, and embargoes issued by these countries oblige SAP to
prevent organizations, legal entities and other parties listed on
government-issued sanctioned-party lists from accessing certain products,
technologies, and services through SAP’s websites or other delivery channels
(e.g. the European Union Sanctions List, the US sanctions lists including the
Bureau of Industry and Security’s (BIS) Denied Persons Lists (DPL), the Office
of Foreign Assets Control’s (OFAC) Specially Designated Nationals and Blocked
Persons List (SDN-List) and the US DOCs Bureau of Industry and Security’s Entity
Lists and the United Nations Security Council Sanctions). SAP processes personal
data to the extent necessary to comply with these legal requirements.
Specifically, SAP processes personal data to conduct automated checks against
applicable sanctioned-party lists, to regularly repeat such checks whenever a
sanctioned-party list is updated or when a user updates his or her information.
In case of a potential match, SAP will block the access to SAP’s services and
systems and contact the user to confirm his or her identity.

 

If necessary, SAP uses personal data to prevent or prosecute criminal activities
such as any form of cybercrime, the illegal use of our products and services or
fraud, to assert our rights or defend SAP against legal claims.

 

To comply with data protection and unfair competition law related requirements.
Depending on the country in which the relevant SAP Group company operates, and
whether you have expressly consented to or opted out of receiving commercial
information, SAP may process personal data necessary to accommodate your data
protection and privacy choices for the receipt of such information and, when
necessary to ensure compliance, exchange such information with the other
entities of the SAP Group.

 

To operate SAP internet pages, web-offerings, or other online events

SAP processes personal data for the purpose of operating, providing to you and
administering your use of SAP’s internet pages, web offerings, or other online
events.

 

Creating user profiles

Certain web offerings linked to SAP’s websites, including forums, blogs, and
networks (e.g., the SAP Community), require you to register and create a user
profile. Through the user profile you can share personal information about you
with other users, such as your name, photo, social media accounts, postal or
email address, telephone number, personal interests, skills, and basic
information about your company. The user profiles serve to personalize the
interactions between the users (for example, by way of messaging or follow
functionality) and to allow SAP to foster the collaboration and quality of
communication through such offerings. The profile settings of the relevant web
offering allow you to determine which information you want to share.

 

Identity service

The user profile may be specific to a single web offering of SAP, but it also
allows you to access other web offerings of SAP or of other entities of the SAP
Group. It is your choice whether or not to use any of these additional web
offerings. If you do, SAP will make your personal data available to such other
web offering to provide you with initial access. Kindly note that without your
consent for SAP to create such user profiles, SAP will not be able to offer such
services to you where your consent is a statutory requirement that SAP can
provide these services to you.

 

Event profiling

If you register for an event, seminar, or webinar of SAP, SAP may share basic
participant information (your name, company, and email address) with other
participants of the same event, seminar, or webinar to promote the interaction
between the participants and to stimulate the communication and the exchange of
ideas.

 

User experience improvement

SAP processes information that relates to your visit to our web offerings to
improve your user experience, identify your individual demand and to personalize
the way we provide you with the information you are looking for. For this
purpose, we collect information regardless of whether you register with a user
profile or not.

 

Cookies and similar tools

SAP processes personal data about the users of SAP websites and other web
offerings using cookies or similar technologies for the purposes set out in
SAP’s Cookie Statement. By visiting the “Cookie Preferences” link in the footer
of the SAP.com homepage, you will find further information and have the option
to exercise your cookie preferences.

 

 

To search for talent

SAP is collecting and processing personal data of qualified individuals and
people interested in our career opportunities from various sources. Job
applicants and candidates are asked to apply via the SAP Career Portal,
regardless of whether this is done initiatively or in response to an advertised
posting. SAP collects personal data by means of the Career Portal for the
purposes of carrying out the application procedures and selecting applicants.
You may find further information about how SAP collects and processes
applicant’s data in the Privacy Statement specific to the SAP Careers Portal.

 

To offer SAP products and services

SAP collects and processes personal data for sales and marketing purposes. We
aim to keep you updated on upcoming events and SAP’s latest products and
services. If possible, we may contact you to discuss further your interest in
SAP services and offerings.

 

Request feedback, questionnaires and surveys

To the extent allowed by applicable law, SAP may contact you for feedback
regarding the improvement of the relevant material, product, or service. SAP may
also invite you to participate in questionnaires and surveys. These will
generally be designed so you can participate without having to provide
information that identifies you as a participant. If you nonetheless provide
your personal data, SAP will use it for the purpose stated in the questionnaire
or survey or to improve its products and services.

 

To keep you up to date

Within an existing business relationship between you or your employer and SAP,
SAP processes your personal data to inform you about SAP products or services
which are similar or relate to products and services you or your employer have
already purchased or used. SAP will inform you by email or phone about such news
only as far as it is allowed by law, or if SAP has collected such information in
the context of the business relationship. You are entitled to object to SAP’s
use for this purpose at any time by selecting the opt-out option at the bottom
of each marketing related approach.

 

Personalized Content

SAP processes information about your interactions with SAP across its various
business areas and its offerings (your or your employers prior and current use
of SAP products or services, your participation in and use of SAP’s web
offerings, events, white papers, free trials or newsletters) to provide you with
the requested products and services and to improve our personal communications
with you. This data may also be used to efficiently operate SAP’s business,
which also includes: the automation and aggregation of data to support various
analytic and statistical efforts, performance and predictive analytics and
exploratory data science to support your customer journey and to fulfill such
requests. To the extent permitted by law, SAP may combine and use such
information in an aggregated manner to help us understand your interests and
business demands, develop our business insight and marketing strategies, and to
create, develop, deliver, and improve our personalized communications with you.
It may also be used by SAP to display relevant content on SAP owned or
third-party websites.

 

Advertising ID’s

Provided your consent or to the extent permitted by applicable law, SAP may
create a hashed user ID to provide to third party operated social networks or
other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google).
This information is then matched against the third party’s own user database to
display to you more relevant SAP content.

WHAT PERSONAL DATA DOES SAP PROCESS?

SAP processes various types of personal data about the people we interact with
when conducting our business or operating our various web presences and other
communication channels.

 

Depending on the individual case, this may comprise the following types of
personal data:

 

Contact Data

SAP processes the following categories of personal data as contact data: first
name, last name, email addresses, postal address/location (country,
state/province, city), telephone numbers, and your relationship history with
SAP.

 

Personal data related to the business relationship with SAP

In the context of established business relationships, SAP processes the business
partners company name, industry, your job title and role, department and
function and your company’s relationship history to SAP. If you provide a credit
card number or bank details to order products or services, SAP will collect this
information to process your payment for the requested products or services.

 

Compliance related personal data

If required by statutory law or regulation, SAP may process data categories like
date of birth, academic credentials, identity cards or other ID numbers,
geolocation, business partner relevant information about e.g., significant
litigation or other legal proceedings, and other export control or custom
compliance relevant information.

 

Data generated through your use of, or participation in, SAP's internet pages,
web, or online offerings

 

Usage data

SAP processes certain user related information, e.g., info regarding your
browser, operating system, or your IP address when you visit SAP’s web
properties. We also process information regarding your use of our web-offerings,
like the pages you visit, the amount of time you spend on a page, the page which
has referred you to our page and the links on our sites you select.

 

Registration data

SAP may process your contact data as set out above and other information which
you may provide directly to SAP if you register for any of SAP's events or other
web services.

 

Participation data

When you participate in webinars, virtual seminars, events, or other SAP web
services, SAP may process your interactions with the relevant webservice to
organize the event including its sessions, polls, surveys, or other interactions
between SAP and/or its participants. Depending on the event and subject to a
respective notification of the participants, SAP may collect audio and video
recordings of the event or session.

 

Special categories of personal data

In connection with the registration for an event, SAP may ask for your dietary
preferences or information about potential disabilities for purposes of
consideration for the health and well-being of our guests. Any collection of
such information is always based on the consent of the participants. Kindly note
that if you do not provide such information about dietary preferences, SAP may
not have the opportunity to respond to such requests at the time of the event.

 

Personal data received during an application for a job at SAP

SAP processes personal data of individuals applying for a job at SAP as set out
in the privacy statement of the SAP Career Portal.

 

Personal data received by third parties, including publicly available sources

 

SAP generally aims to collect personal data directly from the data subjects. If
you or applicable law allows SAP to do so, SAP may obtain personal data also
from third party sources. These third-party sources may include:

 

your employer in the context of its business dealings with SAP and/or the SAP
Group,

 

third parties you directed to share your personal data with SAP,

 

third party sources and publicly available sources like business oriented social
networks or information broker.

 

When we collect personal data from third party sources, established internal
controls aim to ensure that the third-party source was permitted to provide this
information to SAP and that we may use it for this purpose. SAP will treat this
personal data according to this Privacy Statement, plus any additional
restrictions imposed by the third party that provided the personal data to SAP
or by applicable national law.

 

Personal data necessary for customer satisfaction

To the extent permitted by law or based on your consent, SAP may combine the
information we collect either directly or indirectly about specific users to
ensure the completeness and correctness of the data and to help us better tailor
our interactions with you and determine the information which best serves your
respective interest or demand.

HOW LONG DOES SAP PROCESS MY PERSONAL DATA?

SAP processes your personal data only for as long as it is required:

 * to make products and services requested by you or your employer available to
   you;
 * for SAP to comply with statutory obligations to retain personal data,
   resulting inter alia e.g. from applicable export, finance, tax or commercial
   laws;
 * to fulfill SAP’s legitimate business purposes as further described in this
   Privacy Statement, unless you object to SAP’s use of your personal data for
   these purposes;
 * until you revoke a consent you previously granted to SAP to process your
   personal data. To learn more about how you may revoke consent, please see
   guidance below in section titled, “What are your data protection rights".

SAP may process your personal data for product or service development until this
no longer necessary or SAP is informed that your relationship with the SAP
customer has changed.

 

SAP may retain your personal data for additional periods if necessary for
compliance with legal obligations to process your personal data or if the
personal data is needed by SAP to assert or defend itself against legal claims.
SAP will retain your personal data until the end of the relevant retention
period or until the claims in question have been settled.

WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Your personal data may be passed on to the following categories of third
parties:

 

Entities of the SAP Group

As SAP is selling its products and services to its customers only via local
business relationships, SAP may transfer your personal data to the locally
relevant SAP group entity for the purpose and to the extent necessary to conduct
a business relationship. Other entities of the SAP Group may also receive or
gain access to personal data either when rendering group internal services
centrally and on behalf of SAP SE and the other SAP group entities or when
personal data is transferred to them on a respective legal basis. In these
cases, these entities may process the personal data for the same purposes and
under the same conditions as outlined in this Privacy Statement. The current
list of SAP Group entities can be found here. If you would like to find out
which SAP group entity is responsible for the business relationship with you or
your employer, please contact us at webmaster[@]sap.com.

 

Third party service providers

SAP may engage third party service providers to process personal data on SAP’s
behalf, e.g., for consulting or other services, the provision of the website,
the fulfillment and provisioning of offers from SAP or newsletter dispatch.
These service providers may receive or are granted with access to personal data
when rendering their services and will constitute recipients within the meaning
of the relevant DP law, including GDPR.

 

SAP partners

With your consent or as otherwise indicated by your request, including to
fulfill your ordered services, SAP may share your personal data with designated
partner companies to provide you the product or service you have requested.

 

Other third parties

SAP may transfer your registration data based on your consent or as otherwise
indicated by your request to companies listed on the registration page of an SAP
seminar, webinar or event. These companies may receive your personal data as
co-organizer or sponsor of the event and will use your registration data for the
purposes of their participation in the event. They will provide you directly
with any legally required information about their processing purposes and how
you may exercise your rights.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

Right to access, correct and delete

You can request from SAP at any time access to information about which personal
data SAP processes about you and, if necessary, the correction or deletion of
such personal data. Please note, however, that SAP can or will delete your
personal data only if there is no statutory obligation or prevailing right of
SAP to retain it. If you request from SAP to delete your personal data, you may
not be able to continue to use any SAP service that requires SAP’s use of your
personal data.

 

Right to receive personal data back from SAP

If SAP uses your personal data based on your consent or to perform a contract
with you, you can further request from SAP a copy of the personal data you
provided to SAP. In this case, please contact webmaster[@]sap.com and specify
the information or processing activities to which your request relates, the
format in which you would like to receive the personal data, and whether it
should be sent to you or another recipient. SAP will carefully consider your
request and discuss with you how it can best be fulfilled.

 

Right to restrict

 

You can request from SAP to restrict your personal data from further processing
in any of the following events:

 

you state the personal data about you is incorrect, subject to the time SAP
requires to check the accuracy of the relevant personal data,

 

there is no legal basis for SAP to process your personal data and you demand SAP
to restrict your personal data from further processing,

 

SAP no longer requires your personal data, but you state you require SAP to
retain such data to claim or exercise legal rights or to defend against third
party claims, or

 

in case you object to the processing of your personal data by SAP based on SAP’s
legitimate interest (as further set out below), subject to the time required for
SAP to determine whether it has a prevailing interest or legal obligation in
processing your personal data.

 

Right to object

If and to the extent SAP is processing your personal data based on SAP's
Legitimate Interest, specifically where SAP pursues its legitimate interest to
engage in direct marketing or to apply profiling in relation to direct
marketing, you have the right to object to such a use of your personal data at
any time. When you object to SAP's processing of your personal data for direct
marketing purposes, SAP will immediately cease to process your personal data for
such purposes. In all other cases, SAP will carefully review your objection and
cease further use of the relevant information, subject to SAP’s compelling
legitimate grounds for continued use of the information, which may override your
interest in objecting, or if SAP requires the information for the establishment,
exercise, or defense of legal claims.

 

Right to revoke consent

Wherever SAP is processing your personal data based on your consent, you may at
any time withdraw your consent by unsubscribing or giving us respective notice
of withdrawal. In case of withdrawal, SAP will not process personal data subject
to this consent any longer unless legally required to do so. In case SAP is
required to retain your personal data for legal reasons your personal data will
be restricted from further processing and only retained for the term required by
law. However, any withdrawal has no effect on past processing of personal data
by SAP up to the point in time of your withdrawal. Furthermore, if your use of
an SAP offering requires your prior consent, SAP will no longer be able to
provide the relevant service (or services, if you revoke the consent for SAP to
use your profile under the SAP Identity Authentication Service for multiple SAP
offerings), offer or event to you after your revocation.

 

Right to lodge a complaint

 If you take the view that SAP is not processing your personal data in
accordance with the requirements in this Privacy Statement or under applicable
data protection laws, you can at any time, to the extent required by applicable
law, lodge a complaint with your locally relevant data protection authority,
specifically when you are located in an EEA country, or with the data protection
authority of the country or state where SAP has its registered seat.

HOW CAN YOU EXERCISE YOUR DATA PROTECTION RIGHTS?

Please direct any requests to exercise your rights to webmaster[@]sap.com

HOW WILL SAP VERIFY REQUESTS TO EXERCISE DATA PROTECTION RIGHTS?

SAP will take steps to ensure it verifies your identity to a reasonable degree
of certainty before it will process the data protection right you want to
exercise.  When feasible, SAP will match personal data provided by you in
submitting a request to exercise your rights with information already maintained
by SAP. This could include matching two or more data points you provide when you
submit a request with two or more data points that are already maintained by
SAP. 

SAP will decline to process requests that are manifestly unfounded, excessive,
fraudulent, represented by third parties without duly representing respective
authority or are otherwise not required by local law.

CAN I USE SAP’S PRODUCTS AND SERVICES IF I AM A MINOR OR CHILD?

In general, SAP websites and online services are not directed to users below the
age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you
are younger than 16, you cannot register with and use these websites or online
services.

ADDITIONAL COUNTRY AND REGIONAL SPECIFIC PROVISIONS

Where SAP is subject to privacy requirements in the EU, EEA, or other GDPR
relevant countries

 

Who is the Data Protection Officer of the Controller?

You can reach SAP Group’s data protection officer any time at privacy[@]sap.com.

 

Who is the relevant Data Protection authority of the Controller?

SAP’s lead data protection supervisory authority is in Germany, the
Landesbeauftragter für den Datenschutz und die Informationsfreiheit
Baden-Württemberg and can be reached at Lautenschlagerstraße 20, 70173
Stuttgart. If you are in any other EU or EWR country, you may find the contact
details of your competent data protection supervisory authority here.

 

What are the legal permissions for SAP to process personal data?

SAP is processing your personal data for the business purposes set out above
based on the following legal permissions:

 

General remark regarding SAP’s processing of personal data based on your prior
consent

SAP may process your personal data for the specific processing purposes based on
your prior consent.

 

General remark regarding SAP’s processing of personal data based on legitimate
business interest

Where we refer to GDPR Article 6.1 (f) and consequently SAP’s legitimate
business interest as our legal permission to process your personal data, SAP is
pursuing its legitimate business interests

 

to efficiently manage and perform its business operations,

 

to maintain and operate intelligent and sustainable business processes in a
group structure optimized for the division of labor and in the best interest of
our employees, customers, partners, and shareholders,

 

to operate sustainable business relationships with SAP customers and partners
including you (each of which as further set out below),

 

serve you with the best possible user experience when using SAP's web services,

 

comply with extraterritorial laws and regulations, or

 

assert or defend itself against legal claims.

 

We believe that our interest in pursuing these business purposes is legitimate
and thereby not outweighed by your personal rights and interest to refrain from
processing. In any of these cases, we duly factor into our balancing test:

 

the business purpose reasonably pursued by SAP in the given case,

 

the categories, amount and sensitivity of personal data that is necessarily
being processed,

 

the level of protection of your personal data which is ensured by means of our
general data protection policies, guidelines, and processes,

 

and the rights you have in relation to the processing activity.

 

If you wish to obtain further information on this approach, please contact
webmaster[@]sap.com.

 

Pursue business relationships with customers, partners, and others

When pursuing business relationships with customers, partners and others, SAP
and local SAP group entities may be processing personal data based on:


 

GDPR Article 6.1 (b) if necessary, to fulfill (pre-)contractual obligations with
you,

 

GDPR Article 6.1 (c) if necessary, to fulfill legal requirements applicable to
SAP,

 

GDPR Article 6.1 (f) if the contract or pre-contractual relation relates to a
company or other legal body and if SAP processes your personal data as Customer
Contact to fulfill (pre-) contractual obligations with your employer (legitimate
interest to efficiently perform or manage SAP’s business operation)

 

GDPR Article 6.1 (f) if necessary, to maintain our business relationships with
you, ensure your satisfaction as a user or customer representative, and provide
you with information about other SAP products and services as indicated by your
interest or demand (legitimate interest to operate sustainable business
relationship with SAP customers and partners), or

 

a legal permission under other national laws equivalent to any of the above,
when applicable.

 

Ensure compliance with laws and regulation

When ensuring compliance with applicable laws and regulations, SAP and local SAP
group entities may process your Personal data based on


 

GDPR Article 6.1 (c) if necessary, to fulfill legal requirements under European
Union or EU Member State law to which SAP is subject,

 

GDPR Article 6.1 (f) if necessary, to fulfill laws and regulations
extraterritorial to the EU (legitimate interest to comply with extraterritorial
laws and regulations),

 

or the equivalent articles under other national laws, when applicable.

 

Operate SAP internet pages, web offering, or other online events

When operating its internet pages, web-offerings or other online events
("web-services") and depending on the respective operating purpose, SAP or the
local SAP group entity is processing your personal data on the basis of the
following legal permissions:


 

GDPR Article 6.1 (b) and (f) to provide the web services and functions, create
and administer your online account, updating, securing, troubleshooting the
service, providing support, improving, and developing the web service, answering
and fulfilling your requests or instructions, (legitimate interest to
efficiently perform or manage SAPs busines operation)

 

GDPR Article 6.1 (c) and (f) to manage and ensure the security of our web
services and prevent and detect security threats, fraud or other criminal or
malicious activities and as reasonably necessary to enforce the web services
terms, to establish or preserve a legal claim or defense, to prevent fraud or
other illegal activities, including attacks on our information technology
systems (legitimate interest to efficiently perform or manage SAP’s business
operation and assert or defend itself against legal claims)

 

GDPR Article 6.1 (a) if it is necessary that we ask you for your consent to
process your personal data

 

or equivalent legal permissions under other relevant national laws, when
applicable.

 

Cookies and similar tools

When tracking and evaluating the usage behavior of users of our web services by
means of cookies or similar technologies, SAP is processing your personal data
on the basis of the following legal permissions:


 

GDPR Article 6.1 (a) if it is necessary that we ask you for your consent to
process your personal data,

 

GDPR Article 6.1 (b) if necessary to fulfill (pre-)contractual obligations with
you,

 

GDPR Article 6.1 (f) if necessary to fulfill (pre-)contractual obligations with
the company or other legal body you represent as a customer contact (legitimate
interest to efficiently perform or manage SAP’s business operation),

 

or equivalent legal permissions under other relevant national laws, when
applicable.

 

Collection of data from third parties, including publicly available sources

When collecting personal data about you from third parties, the legal basis for
the collection by SAP or the local SAP group entity may be based on:


 

GDPR Article 6.1 (a) if it is necessary that we or the third party transferring
your personal data to SAP has asked you for your consent to process your
personal data,

 

GDPR Article 6.1 (b) if necessary to fulfill (pre-)contractual obligations with
you,

 

GDPR Article 6.1 (c) if necessary to fulfill legal requirements under European
Union or EU Member State law to which SAP is subject,

 

GDPR Article 6.1 (f) if necessary to fulfill laws and regulations
extraterritorial to the EU (legitimate interest to comply with extraterritorial
laws and regulations) or to maintain our business relationships with you, ensure
your satisfaction as a user or customer representative, and provide you with
information about other SAP products and services as indicated by your interest
or demand (legitimate interest to operate sustainable business relationship with
SAP customers and partners)

 

or equivalent legal permissions under other relevant national laws, when
applicable.

 

Offering SAP products and services

When engaging in marketing activities, SAP is processing your personal data on
the basis of the following legal permissions:


 

GDPR Article 6.1 (a) if your consent is required by law for SAP to process your
data for this purpose,

 

GDPR Article 6.1 (f) if necessary to fulfill (pre-)contractual obligations with
the company or other legal body you represent as a customer contact (legitimate
interest to efficiently perform or manage SAP’s business operation), to maintain
our business relationships with you or your employer, to ensure your
satisfaction as a user or customer contact, to map the relevant group internal
structures and bundle relevant business activities at central sources within the
SAP Group to operate them uniformly and to provide you with information about
other SAP products and services as indicated by your interest or demand, which
may also comprise the combination about you from different sources (profiling)
(legitimate interest to maintain and operate intelligent and sustainable
business processes in a group structure optimized for the division of labor and
in the best interest of our employees, customers, partners, and shareholders and
to operate sustainable business relationship with SAP customers and partners).
SAP may provide you with this information to your postal address to pursue our
legitimate interest to address customers, prospects and targets for the purpose
of advertising our products and services, to your email address for the purpose
of direct marketing of similar products or services provided that we (i)
received your email address in connection with the purchase of our products or
services, (ii) you did not object to the use of your email address for direct
advertising and (iii) and we inform you in every approach that you may object to
our use of your email address for marketing purposes at any time, and by other
electronic means (e.g., telephone, MMS) to the extent permitted under applicable
law, generally either explicit or presumed consent,

 

or equivalent legal permissions under other relevant national laws, when
applicable.

 

 

How does SAP justify international data transfers?

As a global group of companies, SAP has group affiliates and uses third party
service providers also in countries outside the European Economic Area (the
“EEA”). SAP may transfer your personal data to countries outside the EEA as part
of SAP’s international business operations. If we transfer personal data from a
country in the EU or the EEA to a country outside the EEA and for which the EU
Commission has not issued an adequacy decision, SAP uses the EU standard
contractual clauses to contractually require the data importer to ensure a level
of data protection consistent with the one in the EEA to protect your personal
data. You may obtain a copy (redacted to remove commercial or irrelevant
information) of such standard contractual clauses by sending a request to
privacy[@]sap.com. You may also obtain more information from the European
Commission on the international dimension of data protection here.

 

Where SAP is subject to certain privacy requirements in the United States, the
following also applies:

U.S. Children’s Privacy. SAP does not knowingly collect the personal data of
children under the age of 13.  If you are a parent or guardian and believe SAP
collected information about a child, please contact SAP as described in this
Privacy Statement.  SAP will take steps to delete the information as soon as
possible.  Given that SAP websites and online services are not directed to users
under 16 years of age and in accordance with the disclosure requirements of the
CCPA, SAP does not sell the personal data of any minors under 16 years of age.

 

Where SAP is subject to certain privacy requirements in the United States in the
State of California, the following also applies:

 

You have the right: 

 

to request from SAP access to your Personal Data that SAP collects, uses, or
discloses about you;

 

to request that SAP delete Personal Data about you;

 

to opt-out of the use or disclosure of your sensitive personal information;

 

to non-discriminatory treatment for exercise of any of your data protection
rights; and

 

if you request access to your Personal Data, for such information to be
portable, if possible, in a readily usable format that allows you to transmit
this information to another recipient without hindrance.

 

In accordance with the disclosure requirements under the California Consumer
Privacy Act (“CCPA”), SAP does not sell or share your Personal Data. In the
course of our business activities we may share Personal Data with third parties,
or permit third parties to collect data across various SAP websites.

 

Data Subject Access Requests: 

SAP receives Data Subject Access Requests from across the globe and works to
ensure all valid requests where SAP is the Controller are responded to within
the appropriate timeframe. In accordance with the verification process set forth
in the CCPA, SAP will require a more stringent verification process for deletion
requests, or for Personal Data that is considered sensitive or valuable, to
minimize the harm that might be posed to you by unauthorized access or deletion
of your Personal Data. If SAP must request additional information from you
outside of information that is already maintained by SAP, SAP will only use it
to verify your identity so you can exercise your data protection rights, or for
security and fraud-prevention purposes. 

 

In addition to contacting SAP at webmaster[@]sap.com, you may also exercise your
rights as follows:

You can call toll-free to submit a request using the numbers provided here or
click here - Limit the Use of My Sensitive Personal Information. You can also
designate an authorized agent to submit requests to exercise your data
protection rights to SAP. Such authorized agent must be registered with the
California Secretary of State and submit proof that you have given authorization
for the agent to act on your behalf.”    

 

Where SAP is subject to the requirements of the Brazilian General Data
Protection Law (“LGPD”), the following also applies:

SAP has appointed a Data Protection Officer for Brazil. Written inquiries,
requests or complaints to our Data Protection Officer may be addressed to:

 

Paulo Nittolo Costa

Email: webmaster[@]sap.com

Address: Avenida das Nações Unidas 14171 - Marble Tower – 7th Floor - São
Paulo-SP, Brazil 04794-000

 

When SAP is subject to the requirements of the Malaysian Personal Data
Protection Act ("PDPA"), a Malaysian Bahasa version of this privacy statement is
available.

 

Where SAP is subject to certain privacy requirements in the Philippines, the
following also applies:

For individuals within the Philippines, you may exercise your rights as follows:

You can call or write to SAP to submit a request at:

 

webmaster[@]sap.com

Phone:    +632-8705-2500

Address: SAP Philippines, Inc.

Attn: Data Protection Officer

27F Nac Tower, Taguig City 1632, Philippines

 

The following provisions apply to residents and citizens of the Philippines:

 

You may claim compensation as finally awarded by the National Privacy Commission
or the courts if you suffered damages due to inaccurate, incomplete, outdated,
false, unlawfully obtained or unauthorized use of personal data, considering any
violation of your rights and freedoms as a data subject;

 

If you are the subject of a privacy violation or personal data breach or are
otherwise personally affected by a violation of the Data Privacy Act, you may
file a complaint with the National Privacy Commission.

 

Your Transmissibility Rights. Your lawful heirs and assigns may invoke your
rights at any time after your death or when you are incapacitated or incapable
of exercising your rights.

 

Where SAP is subject to the requirements of the Singapore’s Personal data
Protection Act (“PDPA”), the following also applies:

SAP has appointed a Data Protection Officer for Singapore. Written inquiries,
requests or complaints to our Data Protection Officer may be addressed to:


 

Subject: [Attn.] Tina Bhatia, DPO (Singapore)

Email: webmaster[@]sap.com


Address: Mapletree Business City, 30 Pasir Panjang Rd, Singapore 117440


Contact: +65 6664 6868


 

Where SAP is subject to the requirements of the Protection of Personal
Information Act, 2013 (“POPIA”) in South Africa, the following also applies:

“Personal data” as used in this Privacy Statement means Personal Information as
such term is defined under POPIA.


 

“You” and “Your” as used in this Privacy Statement means a natural person or a
juristic person as such term is used under POPIA.

 

Systems Applications Products (Africa Region) Proprietary Limited & Systems
Applications Products (South Africa) Proprietary Limited with registered address
at 1 Woodmead Drive, Woodmead (SAP South Africa) is subject to South Africa's
Protection of Personal Information Act, 2013 (Act 4 of 2013) and responsible
party under the POPIA.

 

Should you as an individual or a juristic person believe that SAP South Africa
as responsible party has utilized your personal information contrary to POPIA,
you undertake to first attempt to resolve any concerns with SAP South Africa.

 

webmaster[@]sap.com

Phone:    011 325 6000

Address: 1 Woodmead Drive, Woodmead, Johannesburg South Africa 2148

If you are not satisfied with such process, you have the right to lodge a
complaint with the Information Regulator, using the contact details listed
below:

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001, P.O. Box 31533,
Braamfontein, Johannesburg, 2017

Email: complaints.IR[@]justice.gov.za

Enquires:  inforeg[@]justice.gov.za

 

You may request details of personal information which we hold about you under
the Promotion of Access to Information Act 2 of 2000 (“PAIA”). For further
information please review the SAP PAIA manual

 

Where SAP is subject to certain privacy requirements in Turkey, the following
also applies:

When SAP is collecting personal data during the central operation of this
website and other globally operated SAP business activity for residents and
citizens of Turkey and in a manner subject to the requirements of the Law on the
Protection of Personal Data #6698 (“LPDP”) in Tukey, your data controller is:
SAP Türkiye Yazilim Üretim ve Ticaret A.Ş, located in Emaar Square Ofis Kulesi,
Libadiye Cd No:82-F D:Kat: 17-18, 34700 Ünalan/Üsküdar/İstanbul with MERSİS No:
744017604300017 and phone number: +90 216 330 03 00.

 

 

China-Specific Provisions apply to citizens of the People’s Republic of China.

 

Colombia-Specific Provisions apply to citizens of the Republic of Colombia.

 

Russian-Specific Provisions apply to citizens of the Russian Federation





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