Last Updated: April 26, 2018
- Data Protection Officer
- What Information We and Others Collect From You and How it is Collected
- How Your Information Is Used And Processed
- How We Follow Visits And Usage, Why And How You Keep Control (Cookies, Analytics And Advertising)
- How Your Information is Shared
- How Your Information is Kept Safe
- How Your Information Is Transferred Internationally
- How Your Information Is Stored and Retained
- What Privacy Choices and Changes are Available To You
- Your European Privacy Rights
Data Controller: The data controller is the SAP Fieldglass legal entity which initially collects your information and decides how and why to use the data. When you visit an SAP Fieldglass website, the data controller is the SAP Fieldglass entity named in the legal disclosure page on the website. If the local laws that govern the website does not require any specific legal disclosure, the data controller shall be the SAP Fieldglass legal entity named in the copyright notice displayed on such website. We only store the Personal Data as long as legally permissible.
Use of SAP Fieldglass websites by children: SAP Fieldglass’s Channels are not directed to users of an age of below 13 years. If you are younger than 13, you may not use our Channels. If you are a parent or guardian and believe we may have collected information about a child, please contact us at: firstname.lastname@example.org.
SAP’s Data Protection Officer (DPO) is Mathias Cellarius, SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany, who may be contacted at email@example.com; or you may contact our group Privacy Team at any time at firstname.lastname@example.org.
We collect information, called (“Personal Data”), about you directly, indirectly and/or automatically as described below.
To the extent permitted by applicable law, we combine the information collected as described below, including information about the organization for which you work; other information in our possession; or information that you provide to us; and we treat both the combined and unique information as Personal Data.
Direct collection of business information and Personal Data:
When you access, use and/or interact with us through a Channel, we directly collect information you voluntarily provide us. This includes but is not limited to:
- Information about you in the context of your professional activities, such as your name, professional email addresses, and (professional) telephone numbers;
- Information about your company such as the name, size and location of your company and your role within the company;
- Billing and transactional information when purchasing good and services on the Channels;
- Information you may choose to provide us when completing any “free text” boxes on our forms (if any at all, for example in surveys or questionnaires) or when posting information or materials on our chat rooms.
Examples of direct interactions with you through the Channels where you provide us business information and Personal Data about you are the following:
- completion and submission of online (registration) forms (such as events, webinars, webinars recordings, asset download) as part as joint marketing activities with business partners;
- completion of lead cards at events or other forms (either in paper format or electronically) or handing over your business card or badge attendance scanning and other information you provide when you attend a SAP Fieldglass hosted event or visit an SAP Fieldglass booth at a trade show or industry or association event;
- sales inquiries which you initiate (online chat, or dedicated online “contact-us” and “request a quote” forms);
- tele-sales (cold or warm calls) and information you provide during phone calls with sales representatives and tele-sales representatives;
- subscription to marketing communications and/or submission of marketing preference in the SAP Fieldglass Preference Center;
- completion of questionnaires and surveys;
- participation in sweepstakes and contests;
- other conversation data triggered by the above direct interactions (such as follow-up calls and emails, thank-you emails, confirmation emails and the like);
- contacting customer support as part of a contractual or informational request, indirect collection of business information and Personal Data;
We also obtain business information and Personal Data about you from third party sources as permitted by applicable law, such as:
- Information collected by our marketing service providers on our behalf, which are a variety of marketing lead generation service providers, marketing opt-in lists or data aggregators or professional event organizers;
- Information shared with us by SAP Fieldglass business partners as part of their referral activities;
- Public databases or other data you may have made publicly available, such as social media posts on professional networks and social media platforms;
- Information shared with us by the other entities of the SAP group. The current list of the SAP group entities can be found here;
- Information shared with us by a third party who recommended you, once you have confirmed your agreement for us to keep and process such data;
Automatic collection of business information and Personal Data:
When you access, use and/or interact with us through a digital Channel, you do so using a “Device”, which is either a personal computer, desktop or laptop, or a mobile device such as a phone or a tablet for instance. A “Device Identifier” is the number that is automatically assigned to the Device you use to access the digital Channel; it allows us to identify your Device through its Device Identifier. The “Tracking Technologies” are the various technologies we use to automatically collect Device Identifiers and other information about you, such as:
- Information that is logged automatically: your computer's operating system, Internet Protocol (IP) address (including information derived from your IP address such as your geographic location), Device Identifier, access times, browser type, device type, domain name, access times, duration of visit, referring URL, platform, new and repeat information, time stamp and language, and referring website addresses;
- Behavioral data about your usage and activity on the electronic Channels: webpages clicked, websites and content areas visited, content downloaded, date and time of activities;
- Information about your use of social media features such as the Facebook “Like” button, LinkedIn, Twitter and others;
- Past transactional behavior on the Channels based on your prior interactions with us;
- Information obtained from third parties on your interests.
The information collected through Tracking Technologies may be considered Personal Data under applicable data protection laws. For additional information about our use of Tracking Technologies, please see below in How We Follow Visits and Usage, Why and How You Keep Control (Cookies, Analytics and Advertising).
- Legal Basis for Processing: We collect and process your Personal Data with your consent and/or as necessary to provide the goods and services you use on the Channels, fulfill your inquiry, operate our business, meet our contractual and legal obligations, ensure compliance, protect the security of our systems and our customers, or fulfil other legitimate interests.
- Freely Given Consent: As a general principle, granting your consent and providing business information and Personal Data about you is entirely voluntarily and there are no adverse consequences to you if you do not grant a consent when required under applicable law or do not provide the required information. However, there are circumstances where SAP Fieldglass cannot act without certain Personal Data because such information is required such as for instance to process your orders or provide you with access to a web offering or newsletter. In these cases, without the relevant Personal Data, SAP Fieldglass will not be able to provide you with what you requested.
- Purposes of Processing: We use and process Personal Data collected through the Channels for purposes and on the legal basis as described below:
- To Provide the goods or services requested on the Channels.
- When you order such goods or services from us, we communicate with you via email and phone to resolve customer complaints, investigate suspicious transactions, confirm your preferences, send you notice of payments or information about changes to our goods and services, and to send notices, updates, technical notices, security alerts, support and other administrative messages and other disclosures as required by law. For example, when you have registered to attend an SAP Fieldglass hosted event, even if you have unsubscribed from our email marketing and promotional messages, we will still send you emails about related items for this specific event (i.e. additional activities you can sign up for, launch of the event app, schedule changes, etc.). Generally, you cannot opt out of these communications, which are not marketing related but merely required to fulfil your request in the context of the relevant business relationship you initiated.
- To Ensure compliance:
- We use your Personal Data to prevent, detect, mitigate, and investigate fraudulent or illegal activity.
- The information required to track your choices regarding the processing or use of your Personal Data or receiving marketing materials is based on the country law in which the relevant SAP Fieldglass company operates and is stored and exchanged between members of the SAP group as necessary to ensure compliance.
- To Operate and Improve our Channels, goods and services, to keep you up to date, to follow-up on a referral or request your feedback
- SAP Fieldglass processes and uses your Personal Data based on its legitimate interest use cases below.
- Questionnaires and surveys. We may invite you to participate in questionnaires and surveys. If Personal Data is included in questionnaires and surveys, SAP Fieldglass may use such Personal Data for marketing research and to improve its products and services.
- Recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, we may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions to improve the quality of our services.
- Referral follow-up. A follow up contact to you based on a referral from another individual, requesting that the you opt-in to future communication.
- To keep you up-to-date and request feedback. Within an existing business relationship between you and SAP Fieldglass, we may inform you, where permitted in accordance with local laws, about our goods or services (including webinars, seminars, conferences or events) which are similar or relate to such goods and services you have already ordered or used from SAP Fieldglass. In addition, when you have attended a webinar, seminar or event of SAP Fieldglass or purchased goods or services from SAP Fieldglass, we may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, good or service.
- To provide updates about SAP Fieldglass’s goods and services:
- We use your Personal Data collected through the Channels (to (i) keep you up to date on the latest product announcements, product updates, unique offers, and other information regarding SAP Fieldglass’s goods and services (including marketing-related information or newsletters) as well as events of SAP Fieldglass and partners’ offer and (ii) to display relevant content on our Channels and provide a personalized experience and implement the preferences you request.
- With regard to marketing and promotional related types of communication including providing personalized updates about SAP Fieldglass’s goods and services as described above (i.e. emails and phone calls), we will (i) where legally required only provide you with such information after you have granted your consent to such electronic communications (also commonly called “opt-in”) and (ii) provide you the opportunity to exercise an opt-out choice if you do not want to receive further marketing related types of communication from us. We also maintain the SAP Fieldglass Preference Center for you to manage your information, your marketing preferences and exercise your opt-out choices.
- To accommodate your special requirements:
- In connection with the registration for and providing access to an event, conference or seminar we may ask for information about your health for the purpose of identifying and being considerate of individuals with disabilities or special dietary requirements throughout the event. Any such use of information is based on your consent which shall be collected upon your registration to the event, conference or seminar.
- If you do not provide any such information about disabilities or special dietary requirements, SAP Fieldglass will not be able to take any respective precautions.
- Event, Conference, Seminar or Webinar preparation
- If you register for an event, seminar, webinar or conference of SAP Fieldglass we will request your consent first, then may share basic participant information (i.e. your name, company and email address) with other participants of the same event, seminar, webinar or conference to foster the communication and exchange of ideas.
Below are examples of Tracking Technologies that we may use to collect information (and subsequent technology and methods that hereafter used).
First and third-party cookies. We use first and third-party cookies on our Channels. Whether a cookie is 'first' or 'third' party refers to the domain placing the cookie. First-party cookies are those set by a website that you are visiting at the time (e.g., cookies placed by www.fieldglass.com while visiting www.fieldglass.com). Certain cookies are set by a domain other than that of the website you are currently visiting. If you visit a website and another entity sets its cookie or reads its cookie through that website, this would be a third-party cookie (e.g., cookies placed by www.google.com while visiting www.fieldglass.com).
Persistent and session cookies. We use persistent cookies and session cookies on our Channels. Persistent cookies remain on your Device for the period of time specified in the cookie and these are used to remember your preferences within our website. Persistent cookies can remain after you end a browser session. A browser session starts when you open a browser window and finishes when you close the browser window. Session cookies allow us to link your actions during a browser session. Session cookies are created temporarily. Once you close the browser, session cookies are typically deleted.
You can find out more information on cookies at: http://www.allaboutcookies.org/
Web Beacons. We may collect information using web beacons. Web beacons are electronic images that may be used on our websites or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner, ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and HTML5 cookies.
Flash LSOs. When we post videos or other media on our websites, third parties may use local shared objects, also known as Flash cookies, to store your preferences for volume control, or to personalize certain features. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here:
Publisher provided identifiers (PPIDs): these are identifiers we use alongside cookies and other Tracking Technologies in connection with personalized ads and content on our Channels, on third party websites, in applications, in our emails and elsewhere. The PPID allows us to have a consistent identifier for you across devices from which you use our apps and access our sites. This helps us better tailor your ads and content to your interests and helps keep us from showing you the same ads too many times even as you use different devices.
Targeting or Advertising: We and our third-party partners may use information collected using Tracking Technologies on our Channels to learn more about you and your preferences and deliver content, including ads that seem relevant to your interests on our Channels and can be displayed to you on third-party websites and applications. We also may use Tracking Technologies to know when you return to our Channels after visiting these third-party websites and applications. We use information about you collected through Tracking Technologies to try to understand your interests and show you relevant advertising about products and services that may interest you. Our third-party partners may also use this information for third party advertising. Third parties may automatically collect information about your visits to our Channels and other websites, your IP address, your ISP, the browser you use to visit our Channels. They do this by using Tracking Technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Channels and other websites tracked by these third parties. Please note we are not responsible for Tracking Technologies in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Tracking Technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here:
Analytics: We use analytics, including analytics conducted by third party partners, to help improve our Channels and your user experience, such as remembering you when you return, understanding your preferences and interests, and knowing which of our Web pages are visited and which Channels are most often used.
We work with third party vendors, consultants and other service providers that help us run our sales and marketing activities. These companies provide work and services such as email delivery, postal delivery, collecting on our behalf business information and Personal Data about you, event/campaign management (including registration), information technology and related infrastructure provision, data analysis and insight, auditing and other similar services. In some cases, these companies need access to some of your Personal Data in order to carry out their work for us. They are not permitted to use your Personal Data for their own promotional or business purposes.
With your consent, we may transfer your Personal Data to the other entities of the SAP group. The current list of SAP group entities can be found here. Record of your consent to our sharing your information with the other entities of the SAP group is stored in the SAP Fieldglass Preference Center.
With your consent, we may share your contact information with sponsors, co-sponsors and/or exhibitors of events and/or conferences organized and hosted by SAP Fieldglass. Please note that our sponsors, co-sponsors and/or exhibitors may directly request your information at their conference booths or presentations. You should review their privacy policies to learn how they use personal information.
Occasionally, we may engage in joint sales or product promotions with selected business partners to provide content or to host events, conferences and seminars. If you purchase or specifically express interest in a jointly-offered product, promotion or service, we may share relevant Personal Data with those partners with your consent. However, please be aware that we do not control our business partners’ use of such Personal Data. Our partners are responsible for managing their own use of the Personal Data collected in these circumstances. We recommend you review the privacy policies of the relevant partner to find out more about their handling of your Personal Data.
We may also share your information in the following circumstances:
- In an aggregated form that does not directly identify you, such as statistical information about visitors to our Channels.
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of SAP Fieldglass, our users, or others; and in connection with the enforcement of our terms and contracts.
- In connection with a corporate transaction, such as a divestiture, merger, acquisition, consolidation, or asset sale (or the negotiation thereof), or in the unlikely event of bankruptcy. We may assign or transfer your information as part of the transaction.
- As required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served to us.
SAP Fieldglass maintain data handling and storage practices and procedures that are designed to promote the integrity and confidentiality of Personal Data. We update and test our security technology on an ongoing basis. We use commercially acceptable means to protect your personal information to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction, we cannot guarantee its absolute security.
When we transfer Personal Data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, such transfer is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually ensure that your Personal Data is subject to a level of data protection which applies within the EEA. You may obtain a redacted copy (in order to remove commercial and not relevant information) of such Standard Contractual Clauses by sending a request to email@example.com.
For clarity, in circumstances where we are required by mandatory law to retain your Personal Data longer (such as for tax, legal, accounting or other purposes) or where we need your Personal Data to assert or defend against legal claims, we will retain such information until the end of the relevant retention period or the settlement of the claims at stake.
Preference Center & Choices. You can customize and control your marketing communication preferences by updating the Personal Data you provide us and your subscription settings in the SAP Fieldglass Preference Center where you can return at any time to change your elections. You can also unsubscribe from promotional emails by: (1) following the unsubscribe instructions in our emails; or (2) emailing us at firstname.lastname@example.org. You can find details on how to automatically unsubscribe from e-mail communications in the SAP Fieldglass Preference Center. If you have any problems using any of these opt-out mechanisms, please contact us at email@example.com. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with transactional information related to the goods and services you have ordered or requested on the Channels.
Do Not Track. You can manage your preferences in your personal web browser settings as we honor “Incognito” or “Do Not Track” settings.
Analytics & Advertising: We encourage you to review the privacy policies of our third-party advertisers and analytics service providers (http://preferences-mgr.truste.com/) to learn about your choices about information they collect from you. In addition, the Network Advertising Initiative offers information about some of the Internet advertising companies we may use, including how to opt-out of interest based advertising they deliver. To opt-out of Google Analytics web tracking you can download Google Analytics Opt-out Browser Add-on.
We adhere to applicable data protection laws in the European Economic Area, which, if applicable to you, includes the rights described hereafter. If you wish to exercise any privacy right that is available to you, we will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes and/or to complete transactions that you began prior to requesting any deletion.
Right not to provide consent or to withdraw consent: Where we seek to rely on your consent in order to process certain parts of your Personal Data, you have the right not to provide your consent or to withdraw your consent at any time. In case of withdrawal, SAP Fieldglass will not process the Personal Data subject to this consent any longer unless legally required to do so. In case we are required to retain your Personal Data for legal reasons, such data will be restricted from further processing and only retained for the term required by law. Withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, if your use of a good or service requires your prior consent, we will not be (any longer) able to provide the relevant god or service to you after withdrawal of your consent.
Right of Information and Access: You can require SAP Fieldglass to confirm at any time that SAP Fieldglass is processing your Personal Data, or to have access to the Personal Data SAP Fieldglass may have about you. You may also request information about: the purpose of the processing; the categories of Personal Data concerned; who else outside SAP Fieldglass might have received the data from SAP Fieldglass; what the source of the information was (if you didn’t provide it directly to SAP Fieldglass); and how long it will be stored. Reasonable access to your Personal Data will be provided at no cost to you upon request. If access cannot be provided within a reasonable time frame, SAP Fieldglass will provide you with a date when the information will be provided. If for some reason access is denied, SAP Fieldglass will provide an explanation as to why access has been denied.
Right to Rectification: You have a right to correct (rectify) the record of your Personal Data maintained by SAP Fieldglass if it is inaccurate.
Right of Erasure (also called Right to Be Forgotten): In certain circumstances, you may have the right to the erasure of Personal Data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
Right to Data Portability: If SAP Fieldglass uses your Personal Data on the legal basis of either your consent or performance of a contract with you, beyond and above mere information about your Personal Data, you may request from SAP Fieldglass a copy of the Personal Data you provided us, clearly stating which Personal Data you require from SAP Fieldglass in which format and whether the Personal Data shall be provided to you or another recipient. We will carefully review your request and discuss with you how it can be best implemented.
Right to Restriction of Processing: You can request from SAP Fieldglass that SAP Fieldglass restricts your Personal Data from any further processing in certain circumstances (for example, where you believe that the Personal Data we hold about you is not accurate or lawfully held; another example is where you object against the processing of your Personal Data by SAP Fieldglass on the ground of legitimate interest, in such case you have a right to restrict processing of your Personal Data while SAP Fieldglass will verify if it has a prevailing interest in processing your Personal Data).
Other right: As applicable under French law, you can also send us specific instructions regarding the use of your Personal Data after your death.
If you would like to exercise any of the above rights, please contact firstname.lastname@example.org so that we may consider your request under applicable law, verify any relevant legal requirements and exemptions, including steps to verify your identity before complying with the request.
Senior Director for Privacy & Security
111 N. Canal Street, Suite 600
Chicago, Illinois 60606