SAP PRIVACY STATEMENT

This Privacy Statement was updated on May 12, 2026. We have created this Privacy Statement to demonstrate the firm commitment of SAP (hereinafter "We", "SAP", "Us" or "Our") to the individual`s right to data protection and privacy. It outlines how SAP processes information that can be used to directly or indirectly identify an individual (hereinafter “Personal Data”). Processing in the context of this Privacy Statement means any collection, use, transmission, disclosure, erasure or any other similar operation based on Personal Data (hereinafter “Processing” or “Process”).

To view the previous version of this Privacy Statement, click here.

A. General Information

Who is the responsible SAP entity?

The controller of Joule Work is SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany. You can reach SAP Group's data protection officer at privacy@sap.com.

For what purposes does SAP process your Personal Data and based on what legal basis?

Depending on the applicable law, the Processing of Personal Data is subject to a justification, sometimes referred to as legal basis.

SAP's compliance with statutory obligations

When ensuring compliance, SAP processes your Personal Data if and to the extent necessary to fulfill legal requirements under European Union or EU Member State law to which SAP is subject, and laws and regulations extraterritorial to the EU (legitimate interest to comply with extraterritorial laws and regulations).

Providing access to Joule Work

We require your Personal Data to provide you access to Joule Work.

When using Joule Work, SAP processes your Personal Data if and to the extent

What categories of Personal Data does SAP process?

SAP processes the following categories of Personal Data: name, username, home or business address, home or business email address, personal or business phone number, usage tracking data, recorded voice, account information.

If SAP asks you to participate in a survey, SAP will generate and place a random ID on your device. This ID will be stored on your device as long as you use the Joule Work and signals to SAP that your device has already participated in a given survey and/or prevents that this device and therefore you will be presented with the same survey more than once or at too short intervals. Furthermore, together with the responses to the surveys, SAP will collect certain technical information about your device such as the device type or its operation system which will help SAP to interpret your feedback. Please note that neither the IDs nor the technical data allow SAP to identify you or your device. If you do not want to give feedback and/or do not want the above mentioned technical data to be sent with your survey responses, you can just decline to participate in a survey.

If SAP processes special categories of Personal Data under applicable law, SAP will ask you for your consent in a specific declaration.

From What Types of Third Parties does SAP obtain Personal Data?

SAP generally aims to collect Personal Data directly from you. If you obliged by statutory law or contractual requirements to provide Personal Data to SAP and you fail to provide such Personal Data, then kindly note that SAP may not be able to provide you with the respective service and/or business relationship.

If you or applicable law allows Us to do so, We may obtain Personal Data also from Third Party which may include:

When We collect Personal Data from Third Parties, established internal controls aim to ensure that the third-party source was permitted to provide this information to SAP and that We may use it for this purpose. SAP will treat this Personal Data according to this Privacy Statement and any additional restrictions imposed by the third party that provided the Personal Data to SAP or by applicable national law.

How long does SAP store your Personal Data?

SAP may retain your Personal Data for additional periods if necessary for compliance with legal obligations to process your Personal Data or if the Personal Data is needed by SAP to assert or defend itself 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. SAP does only store your Personal Data for as long as it is required:

Who are the recipients of your Personal Data and where will it be processed?

Your Personal Data will be transferred to or accessed by the following categories of third parties to process your Personal Data:

What are your data protection rights and how can you exercise them?

SAP honors your statutory rights when it comes to the Processing of your Personal Data. To the extent provided by applicable data protection laws, you have the right to:

Depending on applicable local data protection laws, your rights may be subject to deviations, limitations, orexceptions as set out in the country specific section “B. Additional Country and Regional Specific Provisions”. Please be aware, that SAP honors your statutory rights when it comes to the Processing of your Personal Data to the extent provided by applicable data protection laws.

How can you exercise your data protection rights?
Please direct any requests to exercise your rights to jouleworkmobile@sap.com.
SAP will take steps to ensure it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, SAP will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by SAP. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by SAP. SAP will decline to process requests that are manifestly unfounded, excessive, fraudulent, represented by third parties without duly representing respective authority or are otherwise not required by local law.

Can you use SAP's services if you are a minor?

In general, Joule Work is not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16 or the equivalent minimum age in the relevant jurisdiction, you cannot register with and use Joule Work.

B. ADDITIONAL COUNTRY AND REGIONAL SPECIFIC PROVISIONS

Where SAP is subject to privacy requirements in the EU/EEA or a country with national laws equivalent to the GDPR

1. Who is the relevant Data Protection Authority?

You may find the contact details of your competent data protection supervisory authority here. SAP's lead data protection supervisory authority is the Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg and can be reached at Lautenschlagerstraße 20, 70173 Stuttgart/Germany.

2. How does SAP justify international data transfers?

As a global group of companies, SAP has group affiliates and uses third party service providers also in countries outside the European Economic Area (the “EEA”). SAP may transfer your Personal Data to countries outside the EEA as part of SAP's international business operations. If We transfer Personal Data from a country in the EU or the EEA to a country outside the EEA and for which the EU Commission has not issued an adequacy decision, SAP uses the EU standard contractual clauses to contractually require the data importer to ensure a level of data protection consistent with the one in the EEA to protect your Personal Data. You may obtain a copy (redacted to remove commercial or irrelevant information) of such standard contractual clauses by sending a request to privacy[@]sap.com. You may also obtain more information from the European Commission on the international dimension of data protection here.

Where SAP is subject to privacy requirements in Australia

Where SAP is subject to the requirements of the Privacy Act 1988 (Cth) ('Privacy Act'), the following applies:

SAP may store your Personal Data in paper-based files or as an electronic record in the Cloud or on physical devices e.g. computer systems. Your Personal Data will likely be held and stored by the SAP Group located in another country for our general business purposes including outsourcing and data processing. We will only do this where it is necessary or appropriate to achieve the purposes set out in this Privacy Statement. We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorized access, modification or disclosure.

You can contact Us either by the telephone number +61 2 9935 4939 or via email at jouleworkmobile@sap.com to exercise the following rights:

Where SAP is subject to privacy requirements in Colombia.

Where SAP is subject to the requirements of the Colombian Statutory Law 1581 of 2012 and Decree 1377 of 2013, the following applies:

Within Colombia you have the right to:

SAP Colombia S.A. may Process your Personal Data by itself or on behalf of the SAP Group, with its main office located at Carrera 9 No 115 – 06, Edificio Tierra Firme Of. 2401 Bogotá D.C., Colombia. You can contact Us either by the telephone number +57-6003000 or via email at jouleworkmobile@sap.com. SAP will be responsible to answer any requests, questions, and complaints that you might have to your right to access, update, correct and delete your Personal Data, or revoke your consent.

Where SAP is subject to the requirements of the Brazilian General Data Protection Law (“LGPD”).

SAP has appointed a Data Protection Officer for BrazilWritten inquiries, requests or complaints to our Data Protection Officer can be send via post to Avenida das Nações Unidas 14171 - Marble Tower – 7th Floor - São Paulo-SP, Brazil 04794-000 or email at privacy[@]sap.com.

Where SAP is subject to privacy requirements in the Philippines.

Where SAP is subject to the Philippine Data Privacy Act and its Implementing Rules and Regulations, the following applies:

The contact details of your local Data Protection Officer/s are as follows:

Where SAP is subject to privacy requirements in South Africa.

Where SAP is subject to the requirements of the Protection of Personal Information Act, 2013 (“POPIA”) in South Africa, the following applies:“Personal Data” as used in this Privacy Statement means Personal Information as such term is defined under POPIA. “You” and “Your” as used in this Privacy Statement means a natural person or a juristic person as such term is used under POPIA. Systems Applications Products (South Africa) Proprietary Limited with registered address at 1 Woodmead Drive, Woodmead (SAP South Africa) is subject to South Africa's Protection of Personal Information Act, 2013 (Act 4 of 2013) and responsible party under the POPIA.

You have the right to:

Where SAP is subject to privacy requirements in the United States of America.

Where SAP is subject to the requirements of the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Acts of 2020 (CPRA), from hereon referred to as “CCPA” or where other US state laws have similar requirements, the following applies:

You have the right to:

How you can exercise your Data Protection Right.

To exercise these rights, or to limit the Sharing of your Personal Information, please contact us via Email at jouleworkmobile@sap.com or via phone at +1-610-661-1000. In accordance with the verification process set forth under US relevant state law (as appropriate), SAP may require a more stringent verification process for deletion requests (or for Personal Data that is considered sensitive or valuable) to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data. If SAP must request additional information from you outside of information that is already maintained by SAP, SAP will only use it to verify your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes. You can designate an authorized agent to submit requests to exercise your data protection rights to SAP. The agent must submit authorization to act on your behalf and, where required by relevant law, the agent must be appropriately registered.

Financial Incentives.

SAP does not offer financial incentives in return for your consent to share your personal information, nor limit service offerings where you opt-out of such sharing (unless sharing is practically necessary to perform the relevant service).

Children's Privacy.

Given that Joule Work is not directed to users under 16 years of age, SAP does not sell or share the personal information of any minors under 16. If you are a parent or guardian and believe SAP collected information about your child, please contact SAP. SAP will take steps to delete the information as soon as possible.

Where SAP is subject to privacy requirements in Singapore.

Where SAP is subject to the requirements of the Singapore's Personal Data Protection Act (“PDPA”), the following applies:

SAP has appointed a Data Protection Officer for Singapore. Written inquiries, requests or complaints to our Data Protection Officer can be send via post to Mapletree Business City, 30 Pasir Panjang Rd, #03-32, Singapore 117440 or email to privacy[@]sap.com with the subject “Data Protection Officer” or can be reached via phone +65 6664 6868.

Where SAP is subject to privacy requirements in South Korea.

Where SAP is subject to the requirements of the South Korea Personal Information Protection Act (“PIPA”), the following applies:

Your personal data may be processed globally.

When personal data is processed across country borders, SAP complies with laws on the transfer of personal data between countries to keep your personal data protected. Your personal data may be transferred to, accessed or processed by the categories of third-parties as described above.

How can you exercise your data protection rights?

SAP has appointed a local Chief Privacy Officer for South Korea. Please direct any enquiries or requests via email at jouleworkmobile@sap.com or via phone at +82-2-2194-2279.

Where SAP is subject to privacy requirements in Malaysia.

Where SAP is subject to the requirements of the Personal Data Protection Act (“PDPA”) of Malaysia, the following applies:

Written inquiries, requests or complaints can be sent to the Data Protection and Privacy Coordinator for Malaysia via email jouleworkmobile@sap.com or can be reached via phone +60 3-2202 6000. SAP has implemented technology, security features and strict policy guidelines to safeguard the privacy of users' Personal Data.

To view the data privacy statement in Bahasa Malaysia (Malay), please click here.

Where SAP is subject to privacy requirements in New Zealand

Where SAP is subject to the requirements of the Privacy Act 2020 ('Privacy Act'), the following applies:

If the Personal Data is not collected, we may not be able to provide you access to Joule Work.

You have the right to:

Where SAP is subject to privacy requirements in Canada

Your Personal Data may be processed globally. If personal data is processed across country borders, SAP complies with laws of the transfer of Personal Data between countries to keep your personal data protected. It may, however, based on the laws of such countries be subject to access by local law enforcement.

Where SAP is subject to privacy requirements of Mexico

Where SAP is subject to the requirements of the Mexican Federal Law for the Protection of Personal Data Held by Private Parties of 2010, the following applies:

You have the right to file a complaint with the National Institute of Transparency Access to Information and Protection of Personal Data (INAI) to assert any disagreement related to the processing of your Personal Data by SAP.

SAP reserves the right to change, modify, add or remove portions of this Privacy Statement at its sole discretion. In such case, SAP shall maintain available a complete version of SAP's Privacy Statement. SAP will notify you of any change or modification to this Privacy Statement via the respective communication channel We have with you, e.g., at Our website.

Where SAP is subject to privacy requirements in India

Where SAP is subject to the requirements of the Digital Personal Data Protection Act, 2023 ('DPDPA') the following applies:

As part of a global group of companies operating internationally, SAP has affiliates (the SAP Group) and third party service providers outside of the Indian region and will transfer your Personal Data to countries outside the India region, subject to any restrictions as may be notified by the Central Government in this regard.

You have the right to:

Please direct any requests/queries to exercise your rights to jouleworkmobile@sap.com. In India, after exhausting the opportunity of redressing the right of grievance, you may lodge a complaint to the Data Protection Board of India.