SAP Learning Hub Privacy Statement
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. With regard to any registration data, this Privacy Statement applies whenever users are registering themselves directly with SAP. Furthermore, this Privacy Statement applies to the tracking of any users and the creation of anonymous data sets relating to any users.
Data Controller. The data controller of https://learninghub.sap.com is SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf ('SAP'). The SAP Group’s data protection officer is Mathias Cellarius (firstname.lastname@example.org).
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 fulfil 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.
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@example.com.
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 firstname.lastname@example.org.
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.
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 or institution name, department name, country, city, region, your job title, role), only to process your order or to provide the requested goods or service, including whether the service is used in accordance with the license terms. It may be also be used for license audit. 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 training.sap.com or other local SAP web presences, contact forms, emails, or telephone. In the case where an SAP product or service specifically for students is purchased, this may include verifying current student status by means of reviewing matriculation status documentation issued by a recognized third level academic institution, which must be provided via upload at the time of purchase. If you do not wish us to perform this check, notify us at email@example.com. In this Privacy Statement, 'goods' and 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 at https://learninghub.sap.com/consent-management.
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.
Questionnaires and surveys. SAP may 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 Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, SAP may use such Personal Data to improve its products and services.
Creation of anonymized data sets. SAP may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve SAP Learning Hub, SAP Live Access, SAP Learning Rooms.
SAP may require your name, (email) address, telephone number, company name and address, your job title and role, or other personal identifiers,to track your SAP Learning Hub, SAP Learning Room and SAP Live Access content usage, log-in information, satisfaction ratings, user post data (excluding the content of these posts) and user learning activity in order to produce anonymized reporting for internal SAP use for the purposes of supporting user enablement, improving the quality of the product offering and for account management purposes. In the case of Private edition or bulk sales licenses, this information may be provided to your organization’s reporting user(s) for reporting purposes.
Recording of chats for quality improvement. In case of chat sessions, SAP may record such chat sessions in order to improve the quality of SAP's services.
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.
Right to object. You may object to SAP using Personal Data for the above purposes at any time by unsubscribing at firstname.lastname@example.org. 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
In the following cases SAP will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations.
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) 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.
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. 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.
Sharing of your data with University Alliance members. If you, as a member of University Alliance (‘UA’), have consented to share your registration data (name, email, institution, and other data you provide during registration) with the University Competence Center and Academic Competence Center locations and other universities which may host UA faculty trainings or other UA events (‘UA members’, a list of which can be found here) for fulfilling event services related to UA, then SAP may share your Personal Data with a UA member to be able to fulfill event services related to UA, such as to send you an invitation, and SAP will transfer your registration data to those UA members and these may contact you by email, phone or by using any other communication address you have provided.
Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://learninghub.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 offer or event to you after your revocation.
Revised and posted as of May 23rd, 2018