SAP Certification Privacy Statement

Protecting the individual's privacy is crucial to the future of our business. 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.

A. General Information

Who is the Data Controller? The data controller of SAP Certification Program offerings (the "Service") is SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf ('SAP') and its data protection officer can be reached at privacy@sap.com.

This Privacy Statement applies where SAP acts as controller of any personal data in connection with its Service. This is the case, where:

You use an activation code (e.g. provided by your employer) to register yourself with the Service;
You buy a Service subscription for yourself;
SAP uses Personal Data for the purposes of conducting license audits, tracks users or anonymizes Personal Data for the purposes of improving the Service notwithstanding it is acting in the provisioning of the Service otherwise as a data processor (see next paragraph).

Apart from the last bullet point above, this Privacy Statement does not apply whenever users are receiving their log-on details for the Service from someone else than SAP. In this case, SAP is not acting as a controller but as a processor.

What Personal Data does SAP collect? If you register for SAP Certification Program offerings, SAP will collect the information you provide to SAP, which consists of your name, (email) address, SAP user ID (if applicable), company name, certification code, certification exam results, date of the exam, certification attempts, and your then created username and password) ("Personal Data").

Why SAP needs your Personal Data? SAP requires your Personal Data to:
provide you with access to the Service; to deliver the ordered goods or services; comply with statutory obligations, including checks required by applicable export laws.
Although providing Personal Data is voluntary, without your Personal Data, SAP cannot provide you with access to the Service.

How long will SAP store my Personal Data? SAP will only store your Personal Data for as long as it is required

to make the Service available to you.
for SAP to comply with its statutory obligations resulting from applicable export laws.
to fulfill the purposes outlined in this Privacy Statement.

SAP will also retain your Personal Data for additional periods if it 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 and where will it be processed? Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:

companies within the SAP Group; and
third party service providers.

As part of a global group of companies operating internationally, SAP has affiliates (the "SAP Group") and third-party service providers outside of the European Economic Area (the "EEA") and will transfer your Personal Data to countries outside of the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, SAP uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy (redacted to remove commercial or irrelevant) of such standard contractual clauses by sending a request to privacy@sap.com. You can also obtain more information from the European Commission on the international dimension of data protection here: European Commission.

What are your data protection rights? You can request from SAP: access at any time to information about which Personal Data SAP processes about you and 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. Kindly note further that if you request that SAP deletes your Personal, you will not be able to continue to use any SAP service that requires SAP´s use of your Personal Data which includes the possibility to verify your status as being certified.

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 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 to receive 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, subject to the time 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 state 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 below) subject to the time 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 elearning@sap.com.

How will SAP verify requests to exercise data protection rights? SAP will take steps to ensure that 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.

In accordance with the verification process set forth in the California Consumer Privacy Act ("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.

SAP will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.

Right to lodge a complaint. If you take the view that SAP is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state in which SAP has its registered seat.

SAP will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.

Can I use SAP's services if I am a minor? Children. In general, this Service is not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16 or the equivalent minimum age in the relevant jurisdiction, you cannot register with and use this Service.

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 Certification Program offerings are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, SAP does not sell the Personal Data of any minors under 16 years of age.

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.

B. Processing based on a statutory permission

Why does SAP need to use my Personal Data and on what legal basis is SAP using it?

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

Processing to fulfill contractual obligation. If you register for the Service using an activation code or if you purchase a Service subscription for yourself, SAP requires your Personal Data to deliver goods or services you order under a contract SAP has with you, to establish a contract for goods or services between you and SAP, and to send you invoices for ordered goods or services. SAP will use your Personal Data to (i) contact you after completion of a certification via email or other communication methods in order to inform you about the results, or to send you exam reminders, or (ii) to follow up with you when you contact SAP about the Service, (e.g. when you claim digital badges). This information may be passed on to your employer you are assigned to at the time of inquiry or an affiliated entity or an authorized representative designated by your employer. SAP processes Personal Data to fulfill contractual obligations pursuant to Article 6 (1) lit. b GDPR or the equivalent article under other national laws, when applicable.

Processing to ensure 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 ("EU") and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargos 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 could 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. Any such use of your Personal Data is based on the permission to process Personal Data in order to comply with statutory obligations (Article 6 para. 1 lit. c GDPR) and SAP‘s legitimate interest (Article 6 para. 1 lit. f GDPR) or the equivalent articles under other national laws, when applicable.

Processing based on SAP's legitimate interest.
SAP can use your Personal Data based on its legitimate interest (Article 6 para. 1 lit. f GDPR) or the equivalent article under other national laws, when applicable as follows:

Fraud and Legal Claims. If required, SAP will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
Questionnaires and survey. SAP could invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, SAP will use this personal data to improve its products and services.
Contract Performance. If you purchase or intend to purchase goods or services from SAP on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a "Customer Contact") and SAP, SAP will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs SAP that you are his replacement, SAP will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
Creation of anonymized data sets. SAP will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates' products and services. These anonymous data sets and information may be provided to your employer for reporting purposes.
Personalized Newsletter. If you opt-in to receive marketing communications such as newsletters from SAP, SAP will collect and store details of how you interact with the newsletters to help create, develop, operate, deliver and improve our newsletter communications with you. This information is aggregated and used to help SAP provide more useful information and to understand what is of most interest.
Recordings for quality improvement purposes. In case of telephone calls or chat sessions, SAP will record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of SAP's services.
To keep you up-to-date or request feedback. Within an existing business relationship between you and SAP, SAP might 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 might contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.

You can at any time object to SAP`s use of your Personal Data as set forth in this section by sending an email to learning@sap.com. In this case, SAP will carefully review your objection and cease further use of the relevant information, subject to SAP's compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if SAP requires the information for the establishment, exercise or defense of legal claims.

C. Processing based on consent

In the following cases SAP will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6 para. 1 lit. a GDPR) or the equivalent article under other national laws, when applicable.

Global Marketing. In the following cases, SAP will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6 (1) lit. a GDPR). Each below section about a processing operation of Personal Data is linked to one consent statement in the Consent Resource Center. If you re-open this Privacy Statement after you initially grant one or more consents, you will see the full Privacy Statement and not just information on the consents you granted.

News about SAP's Products and Services. Subject to a respective provision and your consent, SAP may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with SAP (prior purchases, participation in webinars, seminars, or events or the use of (web) services) - further details on this topic can be found in the Cookie Statement displayed on the relevant SAP website - in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about SAP's software and services (including marketing-related newsletters) as well as events of SAP and in order to display relevant content on SAP's websites. In connection with these marketing-related activities, SAP may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks' data or the web offerings' own data bases in order to display to you more relevant information.

Creating user profiles. SAP offers you the option to use its web offerings including forums, blogs, and networks (such as the SAP Community) linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.

These profiles may relate to a single web offering of SAP or, if created in the SAP Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of SAP or of other entities of the SAP Group, or both (irrespective of any consent granted under the section "Forwarding your Personal Data to other SAP companies." below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for SAP to create such user profiles SAP will not be in a position to offer such services to you where your consent is a statutory requirement that SAP can provide these services to you.

Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by SAP to foster the quality of communication and collaboration through such offerings and for SAP to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.

Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, SAP may ask for information about your health for the purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant hereunder.

Kindly note that if you do not provide any such information about disabilities or special dietary requirements, SAP will not be able to take any respective precautions.

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 other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas. Forwarding your Personal Data to other SAP companies. SAP may transfer your Personal Data to other entities in the SAP Group. The current list of SAP Group entities can be found here: SAP Group. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above.

Forwarding your Personal Data to other third Parties. At your request, as indicated by your consent, SAP will transfer your registration data to the companies listed on the registration page. The companies will use your registration data for the purposes of their participation in the event and are obliged to delete the data thereafter. If a company intends to use your data for any other purposes, they will contact you to explain how and for which other purposes they will use your registration data.

Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://training.sap.com/consent-management. In case of withdrawal, SAP will not process Personal Data subject to this consent any longer unless legally required to do so. In case SAP is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by SAP up to the point in time of your withdrawal. Furthermore, if your use of an SAP offering requires your prior consent, SAP will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for SAP to use your profile under the SAP Cloud Platform Identity Authentication Service for multiple SAP offerings), offer or event to you after your revocation.

Interaction history across learning offerings. With your consent SAP may process information about your interactions with SAP across its various learning platforms and its learning offerings including your prior and current use of SAP learning products or services, your participation in and use of SAP’s learning websites, online and offline trainings, events, free trials or newsletters. SAP uses your interaction history in order to improve SAP learning offerings, your learning journey and SAP’s personal communications with you.

Your interaction history may also be used to efficiently operate SAP’s business, which includes: aggregation of data to support various analytic and statistical efforts, performance and predictive analytics and exploratory data science.

SAP strives to improve the user experience and strengthen the relevance of information that you receive from SAP. To do so, SAP may combine and use your interaction history to help understanding your learning interests and learning demands, develop our business insight and marketing strategies, and to create, develop, deliver, and improve our personalized communications with learning recommendations for you.

Privacy Statement for the SAP Certification Program

SAP Certification Privacy Statement

A. General Information

B. Processing based on a statutory permission

C. Processing based on consent