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SAP Social Privacy Statement
SAP Social Privacy Statement

Protecting the individual's privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual’s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual (“Personal Data”).

A. GENERAL INFORMATION

When does this Privacy Statement apply? This Privacy Statement applies to Personal Data that you provide to the social media website when you elect to follow the SAP account or which is derived from the Personal Data as outlined below. The use of and any information that is gathered by third party service providers or other web-tracking technologies is outlined below under the Service Providers section.

Data Controller. The data controller of SAP’s social media accounts is SAP America, Inc., 3999 West Chester Pike, Newtown Square, PA 19073, USA (“SAP”). The SAP Group’s data protection officer is Mathias Cellarius (privacy@sap.com).

What does SAP do with my Personal Data? SAP will process the Personal Data provided hereunder only as set out in this Privacy Statement. Where the processing of your Personal Data is based on a statutory permission, you can find information on which Personal Data SAP is processing or using for which purposes in Section B below.

Duration of processing of Personal Data. Where SAP is processing and using your Personal Data as permitted by law (see B. below), SAP will store your Personal Data (i) only for as long as is required to fulfil the purposes set out below or (ii) until you object to SAP’s use of your Personal Data (where SAP has a legitimate interest in using your Personal Data). However, where SAP is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for SAP to assert or defend 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.

Why am I required to provide Personal Data? Most activity on social media websites is public, including your profile information, your time zone and language, when you created your account, and your postings and certain information about your posts like the date and time. You are responsible for your postings and other information you provide through social media services, and you should think carefully about what you make public, especially if it is sensitive information. By following the SAP social medial account, SAP through the services provided by the social media provider and its data processors will access and process your social media posts and profile information.

Where will my Personal Data be processed? As part of a global group of companies, SAP has affiliates and third-party service providers within as well as outside of the European Economic Area (the “EEA”). As a consequence, whenever SAP is using or otherwise processing your Personal Data for the purposes set out in this Privacy Statement, SAP may transfer your Personal Data to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your Personal Data is subject to a level of data protection that applies within the EEA. You may obtain a redacted copy (from which commercial information and information that is not relevant has been removed) of such Standard Contractual Clauses by sending a request to privacy@sap.com.

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

Furthermore, you can request from SAP that SAP restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data SAP has about you is incorrect (but only for as long as SAP requires to check the accuracy of the relevant Personal Data), (ii) there is no legal basis for SAP processing your Personal Data and you demand that SAP restricts your Personal Data from further processing, (iii) SAP no longer requires your Personal Data but you claim that you require SAP to retain such data in order to claim or exercise legal rights or to defend against third party claims or (iv) in case you object to the processing of your Personal Data by SAP (based on SAP’s legitimate interest as further set out in B. below) for as long as it is required to review as to whether SAP has a prevailing interest or legal obligation in processing your Personal Data.

Please direct any such request to privacy@sap.com.

Right to lodge a complaint. If you believe that SAP is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which SAP has its registered seat.

Links to other websites. Social media websites contain links to other websites. SAP is not responsible for the privacy practices or the content of websites outside the SAP Group of companies. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.

B. WHERE SAP USES MY PERSONAL DATA BASED ON THE LAW

In the following cases, SAP is permitted to process your Personal Data under the applicable data protection law.

SAP’s legitimate interest. Each of the use cases below constitutes a legitimate interest of SAP to process or use your Personal Data. If you do not agree with this approach, you may object against SAP’s processing or use of your Personal Data as set out below.

Creation of anonymized data sets. SAP may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.

In order to keep you up-to-date/request feedback. Within an existing business relationship between you and SAP, SAP may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from SAP. Furthermore, where you have attended a webinar, seminar or event of SAP or purchased products or services from SAP, SAP may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.

In order to protect the SAP brand, SAP monitors social media channels, including but not limited to Twitter, Facebook, YouTube, LinkedIn and etc., for activity that presents immediate or potential risk to SAP or its employees. In doing so, SAP may access the data for individual social media accounts, including username, public profile, public comments, @mentions, shares, and replies. SAP may respond directly to you to gather additional information, to address your concerns, or to request other action that may mitigate the risk to SAP or SAP employees.

Right to object. You may object to SAP using Personal Data for the above purposes at any time by (i) accessing and configuring your privacy controls of social media websites to restrict what information you share and by (ii) unfollowing the SAP social account. If you do so, SAP will cease using your Personal Data for the above purposes (that is to say under a legitimate interest set out above) and remove it from its systems unless SAP is permitted to use such Personal Data for another purpose set out in this Privacy Statement or SAP determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.

Service providers. In addition to the information you provide, SAP may also collect information during your visit to social media websites through one or more of the service providers described below. These service providers utilize standard interfaces provided by the social media provider in order to collect, aggregate, and analyze the content and actions you contribute to the social media platform. The details of the information that is provided to service providers can be found in the social media website privacy statement. SAP will use these service providers and the gathered information to better understand public sentiment around SAP’s products and services and to improve its offerings. Using these tools, SAP is also able to collect aggregate data that is not related to a particular individual.

If you wish to opt-out of 3rd party tracking, please review and follow the instructions provided in the social media website privacy statement.

(1) Sprinklr. Sprinklr uses integration APIs provided by various social media service providers to access and analyze the contributions and activities associated with the SAP social media accounts. Reports provided by Sprinklr are provided to SAP on an aggregated basis and may contain user specific information such as username or personal identifiers only if a user directly comments on content published through an SAP account, @mentions an SAP-owned account, or posts content associated with SAP products and themes which are monitored.

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