Privacy Statement for Window to Talent

This Privacy Statement was updated on June 1st, 2023.

SAP PRIVACY STATEMENT

Protecting the individual's privacy is crucial to the future of business. We have created this Privacy Statement to demonstrate the firm commitment of SAP (hereinafter "We", "SAP", "Us" or "Our") in how We handle information that relates to any identified individual or to an identifiable individual (hereinafter “Personal Information”).

For the purpose of this Privacy Statement, “China” refers to the mainland of the People's Republic of China, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan.

This Privacy Statement will help you understand:

Who do We mean when We say SAP in this Privacy Statement
For what purposes does SAP process your Personal Information
Processing based on the legal bases other than “consent”
What categories of Personal Information does SAP process
Why and How We process your Sensitive Personal Information
How long does SAP store your Personal Information
Where does SAP store your Personal Information and Cross-border Transfer of Personal Information
Who are the recipients of your Personal Information
What are your Personal Information protection rights
How can you exercise your Personal Information protection rights
How will SAP verify requests to exercise your Personal Information protection rights
Can I use SAP products and services if I am a minor or child

Who do We mean when We say SAP in this Privacy Statement?

The Personal Information Handler (i.e., controller) of window to talent website is SAP (China) Co., Ltd. This Privacy Statement applies to the collection and processing of Personal Information during the central operation of this website and other globally operated SAP business activities by SAP or other SAP Group entities. You can reach SAP Group’s data protection officer any time at privacy@sap.com.

For what purposes does SAP process your Personal Information?

SAP processes your Personal Information for the purpose of ensuring an adequate level of 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 Information 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, account and network security, replication for loss prevention, detecting security incidents, protection against malicious, deceptive, fraudulent, or illegal activity, and prosecuting 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 laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. Applicable export laws, trade sanctions, and embargoes issued by these countries oblige SAP to prevent organizations, legal entities and other parties listed on government- issued sanctioned-party lists from accessing certain products, technologies, and services through SAP's websites or other delivery channels (e.g. the European Union Sanctions List, the US sanctions lists including the Bureau of Industry and Security'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 and the United Nations Security Council Sanctions). SAP processes Personal Information to the extent necessary to comply with these legal requirements. Specifically, SAP processes Personal Information to conduct automated checks against applicable sanctioned-party lists, to regularly repeat such checks whenever a sanctioned-party list is updated or when a user updates his or her information. In case of a potential 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 Information 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 Information necessary to accommodate your data protection and privacy choices for the receipt of such information and, when necessary to ensure compliance, exchange such information with the other entities of the SAP Group.

To operate SAP internet pages, web-offerings, or other online events

When operating its internet pages, web-offerings or other online events ("Web-Services"), SAP processes your Personal Information for the following purposes:

Creating user profiles

Certain web offerings linked to SAP's websites, including forums, blogs, and networks (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 or email address, telephone number, personal interests, skills, and basic information about your company. The user profiles serve to personalize the interactions between the users (for example, by way of messaging or follow functionality) and to allow SAP to foster the collaboration and quality of communication 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 Information available to such other web offering to provide you with initial access. Kindly note that without your consent for SAP to create 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.

To provide you with access to SAP Job positions and learning resources

We require your Personal Information to acquire talents

Processing based on the legal basis other than “consent”

SAP is allowed by applicable laws to process your Personal Information based on different legal basis. You acknowledge that SAP could process your Personal Information based on one of the following legal bases without the need to obtain consent from you:

the processing is necessary for entering into or performing a contract to which you are a party or is necessary for human resources management under lawful labor policies and collective agreements.

For example, We require your Personal Information (such as your name, contact information) in order to communicate with you and enter into a contract with you.

compliance with legal duties and obligations to which SAP is subject.

For example, We may use your Personal Information to prevent security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that.

in response to public health incidents or to protect the vital interests of natural persons
where such processing as news reporting and media supervision are carried out for protecting public interest, and the processing is within a reasonable scope;
where the Personal Information disclosed by individuals themselves or other legally disclosed Personal Information is processed within a reasonable scope;
other situations provided by applicable laws and regulations.

What categories of Personal Information does SAP process?

Contact Data

SAP processes the following categories of Personal Information as contact data e.g. first name, last name, email addresses, postal address/location (country, state/province, city), telephone numbers, and your relationship history with SAP.

Personal Information related to statutory law or regulation

If required by statutory law or regulation, SAP may process data e.g. like date of birth, academic credentials, identity cards or other ID numbers, geolocation.

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 your browser, operating system, or your IP address when you visit SAP's web properties.

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 or other 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 to organize the event including its sessions, polls, surveys, or other interactions between SAP and/or its participants. Depending on the event and subject to a respective notification of the participants, SAP may collect audio and video recordings of the event or session.

Why and How We Process Your Sensitive Personal Information

Sensitive Personal Information means any Personal Information that once leaked or illegally used, is likely to cause harm to the personal dignity of the relevant natural person or potentially endangers the physical and property safety of the individual, including biometric data, religious belief, special identity, medical/health data, financial account information and location tracking data, etc and Personal Information of minors under the age of 14.

Sensitive Personal Information is subject to additional protections or restrictions by applicable laws and regulations. SAP will only process your Sensitive Personal Information allowed by and comply with the relevant applicable laws and regulations.

For the following specific purposes, we need to process your Sensitive Personal Information, otherwise, these purposes will not be achieved and may affect the rights and interests of yourself or other individuals: In connection with the registration for an event, SAP may ask for your dietary preferences or information about potential disabilities for purposes of consideration for the 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 such information about dietary preferences, SAP may not have the opportunity to respond to such requests at the time of the event.

We will take necessary security measures to safeguard your Sensitive Personal Information according to the applicable laws and regulations.

How long does SAP store your Personal Information

SAP does only store your Personal Information for as long as it is required:

to make job opportunities and learning resources available to you.

SAP may retain your Personal Information for additional periods if necessary for compliance with legal obligations to process your Personal Information or if the Personal Information is needed by SAP to assert or defend itself against legal claims. SAP will retain your Personal Information until the end of the relevant retention period or until the claims in question have been settled.

Where We store your Personal Information and Cross-border Transfer of Personal Information

As a global group of companies, SAP has group affiliates and uses third-party service providers in countries both inside and outside of China. For business necessity, SAP may transfer your Personal Information to countries or regions outside China as part of SAP’s international business operations. If We transfer your Personal Information to a country outside of China, We will comply with the requirement of cross-border transfer of Personal Information under applicable laws and regulations, and will ensure that the activities of overseas recipients in processing Personal Information meet the Personal Information protection standards specified in the applicable laws and regulations, including the requirement to acquire an individual’s consent where the legal basis for processing of their personal information is based on consent. You may, at any time withdraw this consent by submitting a request to window-to-talent@sap.com and providing SAP with a notice of withdrawal.

Who are the recipients of your Personal Information?

Your Personal Information will be passed on to the following categories of third parties to process your Personal Information:

companies within the SAP

What are your Personal Information protection rights?

Right to access, correct and delete

You can request from SAP at any time access to information about which Personal Information SAP processes about you and, if necessary, the correction or deletion of such Personal Information. Please note, however, that SAP can or will delete your Personal Information only if there is no statutory obligation or prevailing right of SAP to retain it. If you request from SAP to delete your Personal Information, you may not be able to continue to use any SAP service that requires SAP's use of your Personal Information.

Right to explain

You can request SAP to explain the Personal Information processing rules.

Right of portability

If you request SAP to transfer your Personal Information to certain designated Personal Information Handler, SAP will provide the channel of transfer provided that the conditions specified by the applicable laws and regulations are met.

Right to obtain a copy of Personal Information

You can request from SAP a copy of the Personal Information you provided to SAP. In this case, please contact window-to-talent@sap.com and specify the information or processing activities to which your request relates, the format in which you would like to receive the Personal Information, 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 stop or restrict

You can request from SAP to stop or restrict your Personal Information from further processing in certain circumstances such as:

you state the Personal Information about you is incorrect, subject to the time SAP requires to check the accuracy of the relevant Personal Information;

there is no legal basis for SAP to process your Personal Information and you demand SAP to stop or restrict your Personal Information from further processing;

SAP no longer requires your Personal Information, but you state you require SAP to retain such information to claim or exercise legal rights or to defend against third party claims.

Right to object to automated decision-making

You can request not to be subject to a decision based solely on automated processing.

Right to revoke consent

Wherever SAP is processing your Personal Information 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 Information subject to this consent any longer unless legally required to do so. In case SAP is required to retain your Personal Information for legal reasons your Personal Information 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 Information by SAP up to the point in time of your withdrawal.

How can you exercise your Personal Information protection rights?

Please direct any requests to exercise your rights to privacy@sap.com, including your rights under the PIPL.

How will SAP verify requests to exercise your Personal Information protection rights?

SAP will take steps to ensure it verifies your identity to a reasonable degree of certainty before it will process the Personal Information protection right you want to exercise. When feasible, SAP will match Personal Information 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 not required by local law.

Can I use SAP 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 14 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 14, you cannot register with and use these websites or online services.