SAP Concur Marketing Privacy Statement

SAP Concur Marketing Privacy Statement

Last Updated: February 1, 2020

Available in the following languages: French, German, English, Italian, Spanish, Chinese, Japanese

This SAP Concur Privacy Statement (“Privacy Statement”) describes the various ways that Concur Technologies, Inc., Concur Holdings (Netherlands) B.V., their subsidiaries, other affiliated and/or related companies, as applicable ("SAP Concur" or "we" or “us” or “our”) process information about you that is collected by SAP Concur in the context of sales and marketing activities through Channels (as defined below) and explains how SAP Concur uses such information for its own business purposes. Please see below in the section called “Data Controller” to better understand which individual SAP Concur legal entity shall be the data controller in any given specific situation. As used in this Privacy Statement, “Personal Data” means any data collected through our Channels that can be used to directly or indirectly identify an individual. The “Channels” are the various SAP Concur online, digital, electronic sites and technologies, such as public-facing sales and marketing websites, software applications, social media pages, chat features and online conversations, tele-prospecting or HTML-formatted e-mail messages we use to pursue our sales and marketing activities. Channels include sales and marketing activities carried out offline, but channels exclude SAP Concur business applications like SAP Concur Travel, Expense or Invoice. If you use SAP Concur business applications like SAP Concur Travel, Expense, or Invoice for which your company, institution, or other providing entity (“Providing Entity”) has subscribed either directly with SAP Concur or indirectly via an authorized reseller, please see the SAP Concur Processor Privacy Statement for information on how we access, use, store, collect or disclose data about you on behalf of your Providing Entity. In this Privacy Statement, “goods and services” includes access to SAP Concur’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings, events, conferences, webinars and seminars.

Data Controller. The data controller in any given situation is the SAP Concur legal entity which decides how and why to use your Personal Data for its business purposes. When you visit a SAP Concur Website, the data controller is the SAP Concur entity named in the legal disclosure page on the Website. If the local laws that govern the website do not require any specific legal disclosure, the data controller shall be the SAP Concur legal entity named in the copyright notice displayed on such Website. When you complete an online (registration) form on a SAP Concur Website, the data controller is the SAP Concur entity that is disclosed on the form.

Representative in the European Economic Area (EEA). If the data controller that collected your Personal Data is not a SAP Concur legal entity based in a EEA country, then the representative for the EEA and Switzerland of such data controller is Concur (Netherlands) B.V., located at Amerikastraat 10, 5232 BE ´s-Hertogenbosch, The Netherlands, which you may contact at any time at Privacy-Request@Concur.com.

Links to other websites. This website may contain links to foreign (meaning non-SAP Group companies) websites. SAP Concur is not responsible for the privacy practices or the content of such foreign websites. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.

Use of SAP Concur websites by children. SAP Concur’s Channels are not directed to users under the age of 13. 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: Privacy-Request@Concur.com . SAP Concur will take steps to delete the information as soon as possible. Given that SAP Concur is not directed to users under 16 years of age and in accordance with the disclosure requirements of the California Consumer Privacy Act (“CCPA”), SAP does not sell the Personal Data of any minors under 16 years of age.

DATA PROTECTION OFFICER

SAP’s Group Data Protection Officer (DPO) is Mathias Cellarius, SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany, who may be contacted at Privacy@sap.com; or you may contact our group privacy team at any time at Privacy-Request@Concur.com.

WHAT INFORMATION WE AND OTHERS COLLECT FROM YOU AND HOW IT IS COLLECTED

We collect your Personal Data. We collect such Personal Data about you directly, indirectly and/or automatically as described below. To the extent permitted by applicable law, we may combine the information collected about you, as described below, including information about the organization for which you work, with other information in our possession or information that you provide to us, and we treat all this information about you 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:

• information about you in the context of your professional activities, such as your name, email address, telephone number and country of residence
• information about your company such as the name, size and location of your company, your role within the company and its type of activity
• 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 include the following:

• completion and submission of online and other forms for events, webinars, webinars recordings, or asset downloads, or to request information about our goods and services and/or as part as joint marketing activities with our business partners
• completion of lead cards at events or other forms, whether in paper or electronic format, providing your business card, badge attendance scanning and other information you provide when you attend an SAP Concur hosted event or visit an SAP Concur booth at a trade show or industry or association event
• sales inquiries which you initiate, such as through online chat, dedicated online “contact-us” link and “request a quote” forms
• tele-sales (if permissible under applicable law) 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 Concur Preference Center or, for users of the SAP Business Exchange, in the account settings of the user’s profile
• 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
• contact information gathering as part of implementation services for our products

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 the following:

• 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 Concur business partners as part of their referral activities, such as travel management companies, third party partners that participate in SAP Concur’s App Center, Platform partners and TripLink partners
• 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 (for the purpose of providing you with updates about SAP Concur’s good and services).

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 smartphone or a tablet. A “Device Identifier” is the number that is automatically assigned to the Device you use to access the digital Channel, and we may 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, more precisely the following information:

• 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, 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, such as 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).

HOW YOUR INFORMATION IS USED AND PROCESSED

Legal Basis for Processing. We collect and process your Personal Data with your consent or as permitted under applicable data protection laws 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 Personal Data or 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 Concur cannot take action without certain Personal Data because such information is required, such as to process your orders or provide you with access to a web offering or newsletter. In these cases, without the relevant Personal Data, SAP Concur will not be able to provide you with what you requested.

Purposes of Processing. We use and process Personal Data about you for purposes described below:

• To Provide the goods or services requested on the Channels. If you order goods or services from SAP Concur, we will use the Personal Data which you enter into our online or other forms (typically your name, email and postal address, country of residence, name of company, phone number, job title and role) to process your order or provide the requested goods or services, such as to process your registration to a SAP Concur hosted event. This also includes taking the steps that are necessary prior to entering this contractual business relationship, such as responding to your related inquiries, comments and questions, providing you with shipping and billing information, and providing customer feedback and support. This may also include conversation data that you may trigger on the Channels (e.g., chat-functionalities or other web appearances, contact forms, e-mails or telephone). 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 Concur 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, such as additional activities you can sign up for, the launch of the event app, event schedule changes or the like. 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. Please note also that we will also use your Personal Data to prevent, detect, mitigate, and investigate fraudulent or illegal activity.
• To Ensure compliance with your choices. We use your Personal Data to ensure compliance with your choices: the information that is indeed 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 Concur company operates and is stored and exchanged between members of the SAP group as necessary to ensure compliance.
• To Ensure compliance with export laws. 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 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 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.
• Legitimate Interest: To Operate and Improve our Channels, goods and services, to keep you up to date, to follow-up on a referral, communicate through social media channels, to append data or request your feedback. SAP Concur processes and uses your Personal Data based on its legitimate interest for the use cases below. Your right to object to processing based on legitimate interest is explained below in “Your European Privacy Rights”:
  • Creation of anonymized data sets. We may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets which will then be used to improve SAP Concur products and services or for insights into our customer behavior for public relations purposes.
  • 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. We may engage in a single follow up contact to you based on a referral from another individual, requesting that you opt-in to future communication. In case that an existing customer contact informs us that you are his replacement, we 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.
  • Social media channel communications. We may engage into communications with you for marketing purposes through social media channels until you request us to not be contacted any longer.
  • Appending data. As described above, we also obtain business and Personal Data about you from third party sources, as permitted by applicable law, such as third-party data aggregators, public databases, or posts on social or professional networking platforms. We may combine this information with information you have provided to us to ensure that our records about you are accurate and provide you with more relevant content.
  • To keep you up-to-date and request feedback. Within an existing business relationship between you and SAP Concur, we may inform you, where permitted in accordance with local laws, about our goods or services, such as webinars, seminars, conferences or events, that are similar or relate to goods and services you have already ordered or used from SAP Concur. In addition, when you have attended a webinar, seminar or event of SAP Concur or purchased goods or services from SAP Concur, we may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, good or service.
• Consent: To provide updates about SAP Concur’s goods and services. Based on your consent, (where legally required), we use business information about you and your Personal Data collected through the Channels as well as an interaction profile based on prior interactions with SAP Concur on the Channels (e.g., prior purchases, product usage data, information gathered during customer support contacts, participation in surveys, webinars, seminars or events or the use of web services or interaction with emails) and adding to profiles through data appending with third party sources in order to (i) keep you up to date on the latest product announcements, product updates, unique offers, and other information regarding SAP Concur’s goods and services (including marketing-related information or newsletters) as well as events of SAP Concur and our partners and (ii) to display relevant content on our Channels and provide a personalized experience and implement the preferences you request. 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 databases in order to display to you more relevant information. With regard to marketing related types of communication including providing personalized updates about SAP Concur’s goods and services as described above, we will (a) 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 (b) 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 Concur Preference Center or, for users of the SAP Business Exchange, settings in the user’s profile, for you to manage your information, your marketing preferences and exercise your opt-out choices.
• To create and maintain a digital community user profile. SAP Concur offers you the option to use web offerings such as forums, blogs, and networks (e.g., the SAP Business Exchange) 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. 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 required under applicable law. Within any web offering, in addition to access, your profile is used to personalize interaction with other users, such as with messaging or “follow” functionality, and by SAP Concur to enhance 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.
• 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 Concur will not be able to take any respective precautions.

HOW WE FOLLOW VISITS AND USAGE, WHY AND HOW YOU KEEP CONTROL (COOKIES, ANALYTICS AND ADVERTISING)

We may use Tracking Technologies to collect information. The following are some examples of Tracking Technologies we may use:

• Cookies. We may automatically collect information using "cookies." Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our electronic Channels and your experience. We use cookies to see which areas and features are popular and to count visits to our websites. If you set your browser not to accept cookies or if you reject cookies (your help screen or manual should tell you how to do this), it may affect certain personalization features or services of our websites.
• 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 the SAP Concur French website while visiting that website). 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 Google while visiting the SAP Concur UK website).
• 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. They can remain on your Device after you visit the website that set them and can be read the next time that you visit the website that created that specific cookie or visit another website with a beacon from the website that dropped the cookie. 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.
• 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.
• Buttons, tools, and content from other companies. Our Channels use interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. These features may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. If you choose to "like" or share information from our Channels through these features, some information from your browser may automatically be sent to the other company and you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your Personal Data.
• Publisher provided identifiers (PPIDs). These are identifiers we use with 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.
• 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.

Managing Preferences. SAP Concur wants you to be in a position to make an informed decision for or against the use of cookies which are not strictly necessary for the website’s technical features. If you elect to reject cookies used for advertising, you will be shown advertising that is less targeted to your interests. This will still allow you to use all of the functionality of the website. SAP Concur differentiates between Required Cookies that are absolutely necessary for the website’s technical features, Functional Cookies that allow SAP Concur to analyze the site usage, and Advertising Cookies that are used by advertising companies to serve ads relevant to your interests. SAP Concur provides you with the option to adjust your preferences in the TrustArc Cookie Consent Manager for Functional and Advertising Cookies. You can access TrustArc at any time by clicking on the Cookie Preferences link in the footer of the webpages of this site.

• Required Cookies. Required Cookies are required to enable core site functionality. These cookies allow SAP Concur to provide you a secure log-in and remember how far you are through an order.
• Functional Cookies. Functional Cookies allow SAP Concur to analyze site usage so it can measure and improve its performance. These cookies allow SAP Concur to remember your log-in details to make sure the website looks consistent. You can adjust your personal preferences by clicking on the Cookie Preferences link found in the footer of the webpage of this site.
• Advertising Cookies. Advertising Cookies are used by advertising companies to serve ads that are relevant to your interests. These cookies allow you to share pages with social networks and to post comments. Further, to serve ads relevant to your interests, you can adjust your personal preferences by clicking on the Cookie Preferences link found in the footer of the webpage of this site.

If you have any problems using the Cookie Preferences link found in the footer of the webpage of this site, please email us at Privacy-Request@Concur.com

HOW YOUR INFORMATION IS SHARED

Transfers to data processors. We work with affiliated and 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 business information and Personal Data about you on our behalf, event/campaign registration and management, information technology and related infrastructure services, data analysis and insight, auditing and other similar services. In some cases, these companies need access to some of your Personal Data to carry out their work for us. They are not permitted to use your Personal Data for their own promotional or business purposes.

Transfers to other controllers. Based on your consent, (where legally required), we may transfer your Personal Data to the other entities of the SAP group for the purposes described above of providing you with updates about SAP Concur’s goods and services. The current list of SAP group entities can be found here. Record of any required consent to our sharing your information with the other entities of the SAP group is stored in the SAP Concur Preference Center.

Based on your consent, (where legally required), we may share your contact information with sponsors, co-sponsors and/or exhibitors of events and/or conferences organized and hosted by SAP Concur (such as SAP Concur Fusion) for their own marketing and promotional purposes. 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 as permitted under applicable law. However, please be aware that we do not control our business partners’ use of such Personal Data. Based on your consent (where legally required), we may also transfer your Personal Data to selected business partners for their own marketing and promotional purposes. 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 information about you as part of an Event, Conference, Seminar or Webinar: If you register for an event, seminar, webinar or conference of SAP Concur, based on your consent we may share basic participant information such as 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.

We may also share your information in the following circumstances:

• in an aggregated form that does not directly or indirectly 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 Concur, 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
• 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, data protection authority request or legal process served to us
• SAP Concur may share your information with a third party if you request SAP Concur to share your information with that third party; please note that the third party, and not SAP Concur, is responsible for its use and disclosure of your information shared by SAP Concur, in fulfillment of your request, with the third party.

HOW YOUR INFORMATION IS KEPT SAFE

SAP Concur maintains 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 Data in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction, but we cannot guarantee its absolute security.

HOW YOUR INFORMATION IS TRANSFERRED INTERNATIONALLY

As part of a global group of companies, SAP Concur has affiliates and third-party service providers within, as well as outside of, the EEA. Therefore, your Personal Data may be transferred, used, processed or stored in the United States or any other country where SAP Concur operates or maintains facilities or call centers, including jurisdictions that may not have data privacy laws that provide protections equivalent to those provided in your home country. We take steps designed to ensure that the Personal Data we collect under this Privacy Statement is processed according to the provisions of this Privacy Statement and applicable law wherever the data is located. By providing your information to us on our Channels, you agree to that transfer, storage, and processing in the United States and other countries outside of the European Union. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Channels. 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 (from which commercial information and information that is not relevant has been removed) of such Standard Contractual Clauses by sending a request to Privacy-Request@Concur.com.

HOW YOUR INFORMATION IS STORED AND RETAINED

We store and retain your Personal Data for as long as necessary to fulfill the purposes described in this Privacy Statement, such as to provide goods and services requested by you, respond to your inquiries or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements, or until you object to SAP Concur’s use of your Personal Data (if SAP Concur’s use of your Personal Data is based on a legitimate interest) or you withdraw your consent (if SAP Concur’s use of your Personal Data is based on your consent). For clarity, in circumstances where we are required by 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 resolution of such claims.

WHAT PRIVACY CHOICES AND CHANGES ARE AVAILABLE TO YOU

Preference Center and 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 Concur Preference Center, or, for users of the SAP Business Exchange, in the account settings of the user’s profile, 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 Privacy-Request@Concur.com. You can find details on how to automatically unsubscribe from e-mail communications in the SAP Concur Preference Center, or, for users of the SAP Business Exchange, in the account settings of the user’s profile. If you have any problems using any of these opt-out mechanisms, please contact us at Privacy-Request@Concur.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.

Cookies. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please see “Managing Preferences” under the “HOW WE FOLLOW VISITS AND USAGE, WHY AND HOW YOU KEEP CONTROL (COOKIES, ANALYTICS AND ADVERTISING)” above. Please remember that if you delete your cookies, or use a different browser or computer, you will need to set your cookies preferences again. If you have any problems using this cookie preference mechanism, please contact us at Privacy-Request@Concur.com.

Do Not Track. If you are a US resident, please be aware that we may not recognize or respond to every type of “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services, but we give you certain choices about how we collect Personal Data as described in this Privacy Statement.

Analytics and Advertising. You can customize and control the privacy practices of our third-party advertisers and analytics service providers through the cookie preferences link on our website where you can also review their privacy policies and learn more about your choices about information they collect from you. Please see “Managing Preferences” under the “HOW WE FOLLOW VISITS AND USAGE, WHY AND HOW YOU KEEP CONTROL (COOKIES, ANALYTICS AND ADVERTISING)” above. 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.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

Your European Privacy Rights

If required by applicable law (e.g. because the SAP Concur entity using this privacy statement has its registered seat in a country of the EEA or you are within a country of the EEA), we adhere to the following rights described below.

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 services that require 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 Privacy-Request@Concur.com and specify the information or processing activities to which your request relates, 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, subject to the time required for SAP Concur to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.

As applicable under French law, you can also send us specific instructions regarding the use of your Personal Data after your death.

California Privacy Rights

For individuals within the State of California, you instead have the right (i) to request from SAP Concur access to your Personal Data that SAP Concur collects, uses, or sells (if applicable) or discloses about you; (ii) to request that SAP Concur delete Personal Data about you; (iii) to opt-out of the sale of Personal Data, if applicable; (iv) to non-discriminatory treatment for exercise of any of your data protection rights; and (v) in case of request from SAP Concur for access to your Personal Data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance. Please note that, in accordance with the disclosure requirements under the CCPA, SAP Concur is exempt from providing a notice pursuant to CCPA to opt-out because SAP Concur does not and will not sell your 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 services that require 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 Privacy-Request@Concur.com or, if you are located in the State of California. SAP Concur will consider your request under applicable law and verify any relevant legal requirements and exemptions. You can also designate another person to submit requests to exercise your data protection rights to SAP Concur. You can give authorization to such person by granting them a limited power of attorney to exercise your data protection rights on your behalf.

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

If you take the view that SAP Concur is not processing your Personal Data in accordance with the requirements in this Privacy Policy 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.

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 us.

For requests from individuals within the State of California, 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 for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Statement from time to time without notice to you other than posting the revised Privacy Statement on the Channels or by providing such notice about or obtaining consent to changes as may be required by applicable law. If we change our Privacy Statement, we will post those changes to this Privacy Statement and change the "last updated" date above. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices.

QUESTIONS

Notwithstanding the right you may have to lodge a complaint as stated above in “How can you exercise your data protection rights?”, if you have any questions about this Privacy Statement or to file any complaint regarding this Privacy Statement, please contact us at the following address:

Concur Technologies, Inc.

601 – 108th Avenue NE, Suite 1000

Bellevue, WA 98004

USA

Attention: Privacy Manager

Telephone: (888) 883-8411

SAP Concur will investigate and attempt to resolve complaints and disputes regarding the collection, use, and disclosure of Personal Data by referencing the privacy principles stated in this Privacy Statement. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at feedback-form.truste.com/watchdog/request.