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, specifically your name, (email) address, company name and address, job title and your role (“Personal Data”) at SAP’s Executive Briefing Centers. Please note that other SAP entities, services and websites may have their own Privacy Statements relating to their processing of personal data.
A. GENERAL INFORMATION
When does this Privacy Statement apply? This Privacy Statement applies to Personal Data that you provide to SAP related to your visit to an SAP Executive Briefing Center, or which is derived from the Personal Data as outlined below.
Data Controller. The data controller of SAP Executive Briefing Center is SAP Global Marketing, 10 Hudson Yards, 51st Floor, New York, NY 10001, United States (“SAP”). The SAP Group’s data protection officer is Mathias Cellarius (firstname.lastname@example.org).
What does SAP do with my Personal Data? SAP will process the Personal Data provided hereunder only as set out in this Privacy Statement. Further information can be found in Sections B. and C. below. in relation to your visit to the Executive Briefing Center.
Duration of processing of Personal Data. Where SAP is processing and using your Personal Data as permitted by law (see B. below) or under your consent (see C. 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), or (iii) until you withdraw your consent (where you consented to SAP 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? As a general principle, your granting of any consent and your provision of any Personal Data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Data. However, there are circumstances in which SAP cannot take action without certain Personal Data, for example because this Personal Data is required to process your orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for SAP to provide you with what you request without the relevant Personal Data.
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 email@example.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.
If SAP uses your Personal Data based on your consent or to perform a contract with you, you may further request from SAP a copy of the Personal Data that you have provided to SAP. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Data is to be sent to you or another recipient. SAP will carefully consider your request and discuss with you how it can best fulfill it.
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 firstname.lastname@example.org.
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.
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.
For security purposes. SAP may use your Personal Data to ensure the security of SAP’s facilities, to confirm meeting attendees and create picture badges for identification during your visit to the Executive Briefing Center.
Questionnaires and surveys. SAP may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, SAP may use such Personal Data to improve its products and services.
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.
Right to object. You may object to SAP using Personal Data for the above purposes at any time by contacting Nils Gliddi at email@example.com. 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.
C. WHERE SAP USES MY PERSONAL DATA BASED ON MY CONSENT
In the following cases SAP will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations.
Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, SAP may ask for information about your health for the purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant by submitting such dietary requirements. Kindly note that if you do not provide any such information about disabilities or special dietary requirements, SAP will not be able to take any respective precautions.
Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder contacting Nils Gliddi at firstname.lastname@example.org. 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 not be (any longer) 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.
Date: June 8, 2018