Privacy Statement for SAP Concur
This Privacy Statement was updated on November 2, 2021
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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").
This Privacy Statement does not apply to Personal Data that SAP Concur may process in the role of processor or service provider on behalf of our customers. If you have questions about SAP Concur’s processing of Personal Data in connection with providing products and services to your organization, please contact your organization.
Who is the Data Controller? The data controller for www.concur.com is Concur Technologies, Inc., 601 108th Avenue NE, Suite 1000, Bellevue, WA 98004 (“SAP Concur”). The SAP Group’s data protection officer can be reached at privacy@sap.com. You may contact the SAP Concur privacy team at any time at Privacy-Request@Concur.com.
What Personal Data does SAP Concur collect? When you visit SAP Concur’s websites, SAP Concur stores certain information about your browser, the operating system, and your IP address. If you interact with SAP Concur by submitting a registration form for an event, requesting information about goods and services, completing a questionnaire, participating in a contest, or engaging with SAP Concur in similar sales and marketing activities, SAP Concur will collect the information you provide to SAP Concur, which may consist of your first and last name, email addresses, telephone numbers, location (country, state/province, city), company name, job title/role, department and function, current relationship to SAP, and your company’s industry. If you provide a credit card number or bank details to order goods or services from SAP Concur, then SAP Concur will collect this information to process your payment for the requested goods or services.
Why does SAP Concur need your Personal Data? SAP Concur requires your Personal Data to provide you with access to this site; to deliver any ordered goods or services; and to comply with statutory obligations, including checks required by applicable export laws. Further information on why SAP Concur needs your Personal Data can be found in Section B, below, if SAP Concur’s use of your Personal Data is based on a statutory permission. Further information on why SAP Concur needs your Personal Data can be found in Section C, below, if SAP Concur’s use of your Personal Data is based on your consent. If SAP Concur’s use of your Personal Data is based on consent, note that the information in this Privacy Statement on respective consent statements for certain types of Personal Data uses can also be found in the SAP Concur Preference Center. As a general matter and although providing Personal Data is voluntary, SAP Concur may not be able to perform or satisfy your request without it; for example, SAP Concur might require your Personal Data to process an order you place, or to provide you with access to a web offering that you requested. In these cases, it is not possible for SAP Concur to satisfy your request without certain Personal Data.
Kindly note that you can order goods or services without providing a consent into SAP Concur’s further marketing operations.
From What Types of Third Parties does SAP Concur obtain Personal Data? In most cases, SAP Concur collects Personal Data from you. SAP Concur might also obtain Personal Data from third parties, if the applicable national law allows SAP Concur to do so. SAP Concur will treat this Personal Data according to this Privacy Statement, plus any additional restrictions imposed by the third party that provided SAP Concur with it or the applicable national law. These third-party sources include:
How long will SAP Concur store my Personal Data? SAP Concur will only store your Personal Data for as long as it is required:
SAP Concur 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 Concur to assert or defend against legal claims, SAP Concur 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 your 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:
As part of a global group of companies operating internationally, SAP Concur 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 Concur 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 Concur: access at any time to information about which Personal Data SAP Concur processes about you and the correction or deletion of such Personal Data. Please note, however, that SAP Concur can or will delete your Personal Data only if there is no statutory obligation or prevailing right of SAP Concur to retain it. Kindly note further that if you request that SAP Concur deletes your Personal Data, you will not be able to continue to use any SAP Concur service that requires SAP Concur’s use of your Personal Data.
If SAP Concur uses your Personal Data based on your consent or to perform a contract with you, you can further request from SAP Concur a copy of the Personal Data that you have provided to SAP Concur. 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 should be sent to you or another recipient. SAP Concur will carefully consider your request and discuss with you how it can best fulfill it.
Furthermore, you can request from SAP Concur that SAP Concur restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data SAP Concur has about you is incorrect, subject to the time SAP Concur requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for SAP Concur processing your Personal Data and you demand that SAP Concur restricts your Personal Data from further processing, (iii) SAP Concur no longer requires your Personal Data but you state that you require SAP Concur 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 Concur based on SAP Concur’s legitimate interest (as further set out below), subject to the time required for SAP Concur to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.
For individuals within the State of California, you instead have the right:
Please note, however, that SAP Concur can or will delete your Personal Data only if there is no statutory obligation or prevailing right of SAP Concur to retain it. Kindly note further that if you request that SAP Concur deletes your Personal Data, you will not be able to continue to use any SAP Concur service that requires SAP Concur’s use of your Personal Data.
How can you exercise your data protection rights? Please direct any requests to exercise your rights to SAP’s group data protection officer may be contacted at Privacy@sap.com, or you may contact the SAP Concur privacy team at any time at Privacy-Request@Concur.com.
For individuals within the State of California, you may also designate an authorized agent to submit requests to exercise your data protection rights to SAP Concur. Such authorized agent must be registered with the California Secretary of State and submit proof that you have given authorization for the agent to act on your behalf.
How will SAP Concur verify requests to exercise data protection rights? SAP Concur 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 Concur will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by SAP Concur. 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 Concur.
In accordance with the verification process set forth in the CCPA, SAP Concur 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 Concur must request additional information from you outside of information that is already maintained by SAP Concur, SAP Concur will only use it to verify your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.
SAP Concur 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 Concur 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 where SAP Concur has its registered seat.
Can I use SAP Concur’s services if I am a minor?
Children. In general, SAP Concur websites and online services are 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 website or online services.
U.S. Children’s Privacy. SAP Concur does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe SAP Concur collected information about a child, please contact SAP Concur as described in this Privacy Statement. SAP Concur will take steps to delete the information as soon as possible. Given that SAP Concur websites and online services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, SAP Concur does not sell the Personal Data of any minors under 16 years of age.
Why does SAP Concur need to use my Personal Data and on what legal basis is SAP Concur using it?
Processing to fulfill contractual obligation. SAP Concur requires your Personal Data to deliver goods or services you order under a contract SAP Concur has with you, to establish a contract for goods or services between you and SAP Concur, and to send you invoices for ordered goods or services. SAP Concur 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 when necessary to fulfill SAP Concur’s contractual obligation includes responding to your related inquiries and providing you with shipping and billing information and to processing your feedback or to provide you with access to the SAP Concur customer support systems, provide support services to you and enable you to download content from the SAP Concur customer support systems. This may also include conversation data that you may trigger via the chat functionalities on SAP Concur’s sites, contact forms, emails, or telephone. In this Privacy Statement, “goods and services” includes access to SAP Concur’s web services, offerings, contests, sweepstakes, other content, customer support services, non-marketing related newsletters, whitepapers, tutorials, trainings and events.
Furthermore, SAP Concur communicates on a regular basis by email with users who subscribe to its services and will also communicate by phone to resolve your or other customer complaints or to investigate suspicious transactions. SAP Concur will use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to its products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications because these communications are required for relevant business relationships and not marketing-related in nature.
For marketing-related communications such as emails and phone calls, SAP Concur will (i) only provide you with such information after you have opted in, if legally required, and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related communications. You can also opt out of marketing-related communications at any time by updating your preferences within the SAP Concur Preference Center or, for users of the SAP Business Exchange, settings in the user’s profile.
Processing to ensure compliance. SAP Concur 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 Concur 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 Concur’s websites or other delivery channels controlled by SAP Concur. 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 Concur’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 Concur‘s legitimate interest (Article 6 para. 1 lit. f GDPR) or the equivalent articles under other national laws, when applicable.
Furthermore, you acknowledge that any information required to track your data protection and privacy choices for processing of your Personal Data, or whether you have expressly consented to or opted out of receiving marketing materials depending on the country in which the relevant SAP Group company operates, may be stored and exchanged between members of the SAP Group as required to ensure compliance.
Processing based on SAP Concur’s legitimate interest. SAP Concur 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:
Right to Object. You can at any time object to SAP Concur’s use of your Personal Data as set forth in this section by updating your preferences within the SAP Concur Preference Center or, for users of the SAP Business Exchange, settings in the user’s profile; or SAP’s group data protection officer may be contacted at Privacy@sap.com, or you may contact the SAP Concur privacy team at any time at Privacy-Request@Concur.com. In this case, SAP Concur will carefully review your objection and cease further use of the relevant information, subject to SAP Concur’s compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if SAP Concur requires the information for the establishment, exercise or defense of legal claims.
Processing under applicable national laws. If the applicable national law allows SAP Concur to do so, SAP Concur will use information about you for a business purpose, some of which is Personal Data
In the following cases, SAP Concur 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).
News about SAP Concur’s Products and Services. Subject to a respective provision and your consent, SAP Concur 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 Concur (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 Concur 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 Concur’s software and services (including marketing-related communications) as well as events of SAP Concur and in order to display relevant content on SAP Concur’s websites. In connection with these marketing-related activities, SAP Concur 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 Concur offers you the option to use its web offerings including forums, blogs, and networks (such as the SAP Concur 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 Concur or may also allow you to access other web offerings of SAP Concur 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 Concur to create such user profiles SAP Concur will not be in a position to offer such services to you where your consent is a statutory requirement that SAP Concur 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 Concur to foster the quality of communication and collaboration through such offerings and for SAP Concur 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 Concur 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 Concur will not be able to take any respective precautions.
Event profiling. If you register for an event, seminar, or webinar of SAP Concur, SAP Concur 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 Concur 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.
Forwarding your Personal Data to other third Parties. At your request, as indicated by your consent, SAP Concur may share your contact information with sponsors, co-sponsors and/or exhibitors of events and/or conferences organized and hosted by SAP Concur (e.g., SAP Concur Fusion) and other identified business partners of SAP Concur that may use your Personal Data pursuant to their respective privacy policies.
Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder. Certain consents may be withdrawn by updating your preferences within the SAP Concur Preference Center or, for users of the SAP Business Exchange, settings in the user’s profile. Otherwise, you may contact the SAP Concur privacy team at any time at Privacy-Request@Concur.com . In case of withdrawal, SAP Concur will not process Personal Data subject to this consent any longer unless legally required to do so. In case SAP Concur 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 Concur up to the point in time of your withdrawal. Furthermore, if your use of an SAP Concur offering requires your prior consent, SAP Concur will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for SAP Concur to use your profile under the SAP Cloud Platform Identity Authentication Service for multiple SAP Concur offerings), offer or event to you after your revocation.
Information gathered by cookies or similar technologies, and any use of such information, is further described in SAP Concur’s Cookie Statement. You can exercise your cookie preferences as outlined in SAP Concur’s Cookie Statement.
Where SAP Concur 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 referring to our Cookie Statement. 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.
General. This General Information section applies to Personal Data that you provide to a social media provider’s (“Social Media Provider”) platform when you follow one of SAP Concur’s accounts on the social media platform (such account is referred to as a “Social Media Channel”), or which is derived from the Personal Data as outlined below. The information is this section supplements information in the Privacy Statement, and in the event of any conflict between this section and the remainder of the Privacy Statement, this section will control.
Personal Data Collected. If you follow the Social Media Channel, SAP Concur will access and process your social media posts and profile information, including your time zone and language, when you created your account on the Social Media Provider’s platform, and certain information about your posts like date and time. SAP Concur requires your Personal Data to provide you with access to the Social Media Channel. Although providing Personal Data is voluntary, without your Personal Data SAP Concur cannot provide you with access to the Social Media Channel.
Personal Data from Third Parties. In most cases SAP Concur collects Personal Data from you through Social Media Channels. SAP Concur might also obtain Personal Data from a third party such as a service provider to SAP Concur, if the applicable national law allows SAP Concur to do so. These third-party sources include SAP group entities’ business dealings with you and third parties you directed to share your Personal Data with SAP Concur.
Sprinklr. SAP Concur engages Sprinklr as a third party service provider. Sprinklr uses standard integration APIs provided by a Social Media Provider to collect, aggregate, and analyze the contributions and activities associated with the Social Media Channel on that Social Media Provider’s platform. This can include the content and actions you contribute to the Social Media Provider’s platform. This information is used by Sprinklr to create reports that it provides to SAP Concur on an aggregated basis. Such reports can include specific information like your username or a personal identifier; however, this is only the case when you directly comment on content that SAP Concur publishes in its Social Media Channel, you @mention an Social Media Channel, or you post content associated with SAP Concur products and themes that are monitored by Sprinklr. SAP Concur uses these reports to better understand public sentiment around SAP Concur’s products and services and to improve its offerings. Sprinklr may also receive information from the Social Media Provider as well. For further details on the information a Social Media Provider makes available to Sprinklr, please visit the Social Media Provider’s privacy statement. You can restrict Sprinklr’s ability to collect information as described in this section by following the instructions in the Social Media Provider’s privacy statement.
Certain processing based on SAP Concur’s legitimate interest. In order to protect the SAP Concur brand, SAP Concur monitors Social Media Channels, including but not limited to Twitter, Facebook, and LinkedIn for activity that presents immediate or potential risk to SAP Concur or its employees. In doing so, SAP Concur may access the data for individual accounts on the Social Media Provider’s platform, including username, public profile, public comments, @mentions, shares, and replies. SAP Concur may respond directly to you to gather additional information, to address your concerns, or to request other action that may mitigate the risk to SAP Concur or SAP Concur employees.
You can at any time object to SAP Concur’s use of your Personal Data as set forth in this section by either accessing and configuring your privacy controls on the Social Media Provider’s platform or by unfollowing the Social Media Channel. If you elect either of these options to object, SAP Concur will: (i) cease using your Personal Data based on its legitimate interest to process Personal Data for the above purposes, (ii) remove it from its systems, unless SAP Concur is permitted to use such Personal Data for another purpose set forth in this Privacy Statement, or (iii) continue to process your Personal Data if SAP Concur determines and demonstrates a compelling legitimate interest to do so.
Facebook. The information in this section concerns the processing of Personal Data via SAP Concur's fan pages on Facebook (hereinafter "SAP Concur Facebook page") and about your additional rights in this context.
Twitter. The information in the following section concerns the processing of your Personal Data via SAP Concur’s Twitter accounts (hereinafter “SAP Concur Twitter Account”) and about your additional rights in this context.