This Privacy Statement was updated on July 10, 2023

SAP Partner Portal Privacy Statement

Protecting the individual's privacy is crucial to the future of business. We have created thisprivacy 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).
CONTENT• Who do we mean when we say SAP in this Privacy Statement?
• For what purposes does SAP process your personal data?
• What personal data does SAP process?
• How long does SAP process my personal data?
• Who are the recipients of your personal data?
• What are your data protection rights?
• How can you exercise your data protection rights?
• How will SAP verify requests to exercise data protection rights?
• Can I use SAP’s products and services if I am a minor or child?
• Additional Country and Regional Specific Provisions

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 businessactivity byo

SAP SE, Dietmar-Hopp-Allee 16 Walldorf 69190, Germany if you are in amember 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 byo

SAP America Inc., 3809 West Chester Pike, Suite 200, Newtown Square, PA
19073, USA if you are in any other country, oroa specific SAP group entity as may be stated in the Additional Country andRegional Specific Provisions at the end of this privacy statement.

•in the context of a pre-contractual or contractual business relationship with you or youremployer by a local SAP group entity•

in the context of a registration form when a specific SAP group entity is directlycollecting personal data for the purpose of registering to a service or event and istherefore presented as the relevant controller on this registration page or website byreferencing 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.
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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 productor service, or engaging in any other relevant action to establish, fulfill and maintain ourbusiness 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 thebusiness 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, andother 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 othermedium 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 youremployer 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, toprovide you with relevant information on our latest product announcements, software
updates or upgrades, events, special offers, and other information about SAP’s softwareand 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 forinternal research, technological demonstration and development, and to help SAP
create, develop, operate, deliver, improve, upgrade or enhance SAP products andservices. SAP may process personal data to create anonymized data sets which may
then be used to improve SAP’s products and services.
To track learning and course completion status:
SAP will process Personal Data to track learning and course completion to report it backto you or your employer, or in a particular external user group based on yourmembership in the external user group.
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 levelof 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, accountand network security, replication for loss prevention, detecting security incidents,
protection against malicious, deceptive, fraudulent, or illegal activity, andprosecuting 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 lawsof various countries including, without limitation, those of the European Unionand its member states, and of the United States of America. Applicable export
laws, trade sanctions, and embargoes issued by these countries oblige SAP toprevent organizations, legal entities and other parties listed on governmentissued sanctioned-party lists from accessing certain products, technologies, andservices through SAP’s websites or other delivery channels (e.g. the European
Union Sanctions List, the US sanctions lists including the Bureau of Industry andSecurity’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 andthe 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 applicablesanctioned-party lists, to regularly repeat such checks whenever a sanctionedparty list is updated or when a user updates his or her information. In case of apotential 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 toaccommodate your data protection and privacy choices for the receipt of suchinformation and, when necessary to ensure compliance, exchange suchinformation 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 andadministering 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, andnetworks (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 oremail address, telephone number, personal interests, skills, and basic
information about your company. The user profiles serve to personalize theinteractions between the users (for example, by way of messaging or follow
functionality) and to allow SAP to foster the collaboration and quality ofcommunication 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 toprovide you with initial access. Kindly note that without your consent for SAP tocreate 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 otherparticipants of the same event, seminar, or webinar to promote the interaction
between the participants and to stimulate the communication and the exchangeof 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 ornot.
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 Partner Portal homepage, you will find further information and have theoption to exercise your cookie preferences.
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 andofferings.
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 dateWithin 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 havealready purchased or used. SAP will inform you by email or phone about suchnews only as far as it is allowed by law, or if SAP has collected such informationin 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 eachmarketing 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 theextent 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 orother web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google).
This information is then matched against the third party’s own user database todisplay to you more relevant SAP content.
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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 andyour company’s relationship history to SAP. If you provide a credit card number or bankdetails to order products or services, SAP will collect this information to process yourpayment for the requested products or services.
Compliance related personal data
If required by statutory law or regulation, SAP may process data categories like date ofbirth, 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 yourbrowser, 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 orother 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 toorganize the event including its sessions, polls, surveys, or other interactions
between SAP and/or its participants. Depending on the event and subject to arespective 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 forthe 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 suchinformation about dietary preferences, SAP may not have the opportunity to respond tosuch requests at the time of the event.
Personal data received by third parties, including publicly available sources
SAP generally aims to collect personal data directly from the data subjects. If you orapplicable 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 SAPGroup,•

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 tothis Privacy Statement, plus any additional restrictions imposed by the third party thatprovided 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 theinformation we collect either directly or indirectly about specific users to ensure thecompleteness 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.
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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;•to make relevant course and learning offerings 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 insection 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.
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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 GroupAs 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 andprovisioning of offers from SAP or newsletter dispatch. These service providers may
receive or are granted with access to personal data when rendering their services andwill constitute recipients within the meaning of the relevant DP law, including GDPR.
In case you subscribe to the SAP Partner Update, SAP will forward your email address,
country, product and solution preferences to Impartner UK Limited, Units 2,3,4, The Old
Brewery Yard Battle, East Sussex, United Kingdom, TN33 0AF. Registered in England.
Company Number: 11360392. Impartner UK Limited use this personal data for sendingout the interest-based newsletter.
SAP partners
With your consent or as otherwise indicated by your request, including to fulfill yourordered 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 indicatedby 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 sponsorof 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 theirprocessing purposes and how you may exercise your rights.
External user groups that you join (e.g. ASUG (Americas' SAP Users' Group is anindependent SAP user group))
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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 todelete 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 orprocessing activities to which your request relates, the format in which you would like toreceive 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 anyof 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 toretain 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 inprocessing 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 ofyour 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 yourobjection 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 interestin objecting, or if SAP requires the information for the establishment, exercise, ordefense 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 thisconsent 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 yourwithdrawal. 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 theconsent for SAP to use your profile under the SAP Identity Authentication Service formultiple 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 withthe 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 yourlocally 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.
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How can you exercise your data protection rights?

Please direct any requests to exercise your rights to webmaster@sap.com
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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 notrequired by local law.
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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.
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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 bereached 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 onyour prior consent
SAP may process your personal data for the specific processing purposes basedon 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 ispursuing its legitimate business interests•to efficiently manage and perform its business operations,•

to maintain and operate intelligent and sustainable business processes ina group structure optimized for the division of labor and in the bestinterest of our employees, customers, partners, and shareholders,•to operate sustainable business relationships with SAP customers andpartners 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 fromprocessing. 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 ofour 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 acompany or other legal body and if SAP processes your personal data as
Customer Contact to fulfill (pre-) contractual obligations with youremployer (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 theabove, 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 underEuropean 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 ("webservices") 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 othercriminal 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 toprocess your personal data•or equivalent legal permissions under other relevant national laws, whenapplicable.

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 toprocess 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 withthe 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, whenapplicable.

Collection of data from third parties, including publicly available sources
When collecting personal data about you from third parties, the legal basis for thecollection 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 toprocess 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 underEuropean 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, andprovide 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, whenapplicable.

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 withthe 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 youremployer, to ensure your satisfaction as a user or customer contact, tomap the relevant group internal structures and bundle relevant businessactivities 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 sustainablebusiness processes in a group structure optimized for the division of laborand in the best interest of our employees, customers, partners, andshareholders 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 orservices, (ii) you did not object to the use of your email address for directadvertising 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, whenapplicable.

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 toa country outside the EEA and for which the EU Commission has not issued anadequacy decision, SAP uses the EU standard contractual clauses to contractuallyrequire 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 removecommercial or irrelevant information) of such standard contractual clauses by sending arequest 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, thefollowing 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 inaccordance 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 theState of California, the following also applies:
Do Not Track. Your browser may allow you to set a “Do not track” preference. Unlessotherwise stated, our sites do not honor “Do not track” requests. However, you may electnot to accept cookies by changing the designated settings on your web browser or,
where available, by referring to our Cookie Statement. Cookies are small text files
placed on your computer while visiting certain sites on the Internet used to identify yourcomputer. If you do not accept cookies, you may not be able to use certain functions andfeatures of our site. This site does not allow third parties to gather information about you
over time and across sites.
You have the right:•

to request from SAP access to your personal data that SAP collects, uses, ordiscloses 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;•

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 toanother recipient without hindrance

In accordance with the disclosure requirements under the California Consumer Privacy
Act (“CCPA”), SAP does not and will not sell your personal data or otherwise permit theuse of your information for any kind of cross-context behavioral advertising. 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 yourrights 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” and send the details to us in an
email. You can also designate an authorized agent to submit requests to exercise yourdata 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 theagent 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 orcomplaints to our Data Protection Officer may be addressed to:Paulo Nittolo Costa
Email: privacy@sap.com
Address: Avenida das Nações Unidas 14171 - Marble Tower – 7th Floor - São PauloSP, 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 isavailable.
Where SAP is subject to certain privacy requirements in the Philippines, thefollowing 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 ofyour 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 yourrights.
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 suchterm 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 Protectionof 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, youundertake 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 andother globally operated SAP business activity for residents and citizens of Turkey and ina 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 TicaretA.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.
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