Revised and posted as of 2023-02-15
- Adding section "Who are the recipients of my Personal Data?"
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”).
B. Where SAP Uses My Personal Data Based on the Law
C. Where SAP Uses My Personal Data Based on My Consent
A. General Information
When does this Privacy Statement apply? This Privacy Statement applies to Personal Data that you provide to SAP or which is derived from the Personal Data as outlined below. The use of and any information that is gathered by cookies or other web tracking technologies is subject to the disclosures and options provided by the TrustArc Consent Manager which can be found by clicking the Cookie Preferences link in the footer.
Data Controller. The data controller of openSAP Microlearning website with URL https://microlearning.opensap.com is SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany ("SAP"). Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection but it is in any case displayed on the individual registration form’s privacy statement. The SAP group’s data protection officer is Mathias Cellarius ([email protected]).
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. 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. Where consent for the processing of your Personal Data is required you can find further information in Section C. below.
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 fulfill 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.
Who are the recipients of my Personal Data? Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:
- Companies within the SAP Group.
- Third-party service providers for the provision of the website.
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 protected].
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 [email protected].
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.
Use of this website by children. This website is not intended for anyone under the age of 16 years. If you are younger than 16, you may not register with or use this website.
Links to other websites. This website may contain links to foreign (meaning non-SAP Group companies) 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. This includes links that are offered as social media buttons. Please consider related information in the Cookie Statement.
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.
Providing the requested goods or services. If you order goods or services from SAP, SAP will use the Personal Data that you enter into the order or registration form (usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role and, if payment is to be made to SAP, credit card number or bank details) only to process your order or to provide the requested goods or service. This may include taking the necessary steps prior to entering into the contract, responding to your related inquiries, and providing you with shipping and billing information and to process or provide customer feedback and support. This may also include conversation data that you may trigger via the chat functionalities on SAP.com or other local SAP web presences, contact forms, emails, or telephone. In this Privacy Statement, “goods or services” includes (access to) SAP's web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.
If you participate in tutorials or trainings provided by SAP, SAP may also track your learning progress in order to make this information available to you. Furthermore, we communicate on a regular basis by email with users who subscribe to our services, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), SAP will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time by sending a request to [email protected].
In the context of the above, the openSAP Microlearning website with URL https://microlearning.opensap.com represent an SAP web service. If you access the openSAP Microlearning, SAP uses your Personal Data in order to provide you with the following services:
- User profile. Based on Personal Data you provided in the registration process of your SAP User ID at SAP Identity Service (IDS), a profile has been created, which you can review under the URL https://accounts.sap.com.
- Authentication and authorization. SAP Identity Service (IDS) provides authentication and authorization services for selected content and functionality of the openSAP Microlearning website. When logging in, the website processes your first name, last name, email address, SAP User ID and user type.
- Roles. Assignment to predefined system roles and provision of system permissions (for example: Viewer, Admin) in order to control contribution and administration.
- Commissioned video display services. In order to provide video content within the openSAP Microlearning website, it is connected with the Kaltura video platform, provided by Kaltura, Inc.; New York, NY 10003; USA. As commissioned data processor of SAP, Kaltura stores, processes videos and distributes them for consumption via the openSAP Microlearning website or mobile app.
- Authenticated usage of video display services. With the first successful login, a Kaltura account is created on the Kaltura video platform by using your personal data, which is provided by the SAP Identity Service (IDS): First name, last name, email address, SAP User ID, user type. Based on such a Kaltura account, additional content and functionality are available to you.
- Commissioned video display services. In order to provide video content within the openSAP Microlearning website, it is connected with the YouTube video platform, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. As commissioned data processor of SAP, Google Ireland Limited stores, processes videos and distributes them for consumption via the openSAP Microlearning website or mobile app.
- Watching progress and history. When logged in, SAP tracks your watching progress and history in order to make it available to you.
- Comments and rating. In order to encourage collaboration and to establish an informal community among users, openSAP Microlearning website allows you, after logging in, to create comments, which are displayed together with your user name. You may hide any of your comments by using the "Remove" button. Further you may rate content by setting likes (heart-shaped icons). Your likes are displayed anonymously. However, they are connected to your account in order to allow you to deactivate them by clicking again.
- Email notifications. If you subscribe to a content channel, SAP communicates with you on a regular basis by email about content of the channel.
Ensuring compliance. 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. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, SAP is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through SAP's websites or other delivery channels controlled by SAP. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to SAP's services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.
Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials (that is to say, depending on the country in which the relevant SAP Group company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of the SAP Group as required to ensure compliance.
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.
- 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.
- Feedback. When logged in, SAP may display feedback questions to you in order to collect your opinions regarding content of the openSAP Microlearning website. Providing such feedback is voluntary. If you respond, SAP stores your feedback answers within your Kaltura account and uses them for repeatedly aggregating anonymized data sets. Based on such data sets, SAP improves the content offer of the openSAP Microlearning website.
- Creation of anonymized data sets. SAP may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets and aggregated usage reports, which will then be used to improve its and its affiliates’ products and services. Also when you are not logged in and interact with a video, the Kaltura video display service uses your IP address for extracting the current country, region, city and Internet Service Provider. The IP address is not stored, the extracted data is anonymous and Kaltura does not collect other information that can link this data back to an identifiable individual.
Right to object. You may object to SAP using Personal Data for the above purposes at any time by sending a request to [email protected]. 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
While you access the the openSAP Microlearning website, SAP will not use your Personal Data that would require your prior consent into the relevant processing operations. However, if you access other SAP websites, you may be asked to grant consent into processing operations of Personal Data.
D. Cookies and Similar Tools
Information gathered by cookies or similar technologies, and any use of such information, is further described in the Cookie Statement of openSAP Microlearning. You can exercise your cookie preferences as outlined in this Cookie Statement.
E. U.S.-Specific Provisions
Where SAP is subject to U.S. privacy requirements, the following also applies:
Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honor “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser. or, where available, by way of the TrustArc Consent Manager if the relevant website contains a link to it. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.
Requirements to Protect Children's Privacy. We do not intend for our websites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact at [email protected].
F. Russia-Specific Provisions
The following applies to users who are resident in the Russian Federation:
The services hereunder are not intended for use by citizens of the Russian Federation who are resident in Russia. If you are a Russian citizen residing in Russia, you are hereby notified that any Personal Data that you input into the services will be solely at your own risk and responsibility, that you expressly agree that SAP may gather your Personal Data and will process this data in the United States and in other countries, and that you will not hold SAP accountable for any potential non-observance of legislation of the Russian Federation.
G. Brazil-Specific Provisions
The following applies to users who are resident in Brazil:
Brazilian Law allows companies to send e-mails to potential customers conditioned to the inclusion of an opt-out mechanism and a link to a privacy statement.