SAP PRIVACY STATEMENT

This Privacy Statement was updated on May 29th, 2024. 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”).

A. General Information

Who is the responsible SAP entity?

The controller of SAP Mobile Start 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. The legal basis varies depending on the applicable law and may be subject to deviations, limitations or exceptions resulting from applicable laws.

SAP's compliance with statutory obligations

• SAP processes your Personal Data for the purpose of ensuring an adequate level of technical and organizational security of SAP's products, services, online events, facilities, and premises. For this, SAP will take the measures necessary to verify or maintain the quality and safety of a product or service which is owned, manufactured by or for, or controlled by SAP. This may comprise the use of Personal Data for sufficient identification and authorization of designated users, internal quality control through auditing, analysis, and research, debugging to identify and repair errors that impair existing or intended functionality, account and network security, replication for loss prevention, detecting security incidents, protection against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such kind of activity. We may further process your name, likeness, and other contact or compliance related data when you visit a local SAP affiliate or lab in the context of access management and video surveillance to protect the security and safety of Our locations and assets.
• SAP and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. Applicable export laws, trade sanctions, and embargoes issued by these countries oblige SAP to prevent organizations, legal entities and other parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through SAP's websites or other delivery channels (e.g. the European Union Sanctions List, the US sanctions lists including the Bureau of Industry and Security's (BIS) Denied Persons Lists (DPL), the Office of Foreign Assets Control's (OFAC) Specially Designated Nationals and Blocked Persons List (SDN-List) and the US DOCs Bureau of Industry and Security's Entity Lists and the United Nations Security Council Sanctions). SAP processes Personal Data to the extent necessary to comply with these legal requirements. Specifically, SAP processes Personal Data to conduct automated checks against applicable sanctioned-party lists, to regularly repeat such checks whenever a sanctioned-party list is updated or when a user updates his or her information. In case of a potential match, SAP will block the access to SAP's services and systems and contact the user to confirm his or her identity.
• If necessary, SAP uses Personal Data to prevent or prosecute criminal activities such as any form of cybercrime, the illegal use of Our products and services or fraud, to assert Our rights or defend SAP against legal claims.
• To comply with data protection and unfair competition law related requirements. Depending on the country in which the relevant SAP Group company operates, SAP may process Personal Data necessary to accommodate your data protection and privacy choices for the receipt of such information and, when necessary to ensure compliance, exchange such information with the other entities of the SAP Group.

When ensuring compliance, SAP processes your Personal Data if and to the extend to fulfill legal requirements under Vietnamese law to which SAP is subject.

Providing access to SAP Mobile Start

We require your Personal Data to provide you access to SAP Mobile Start.

When using SAP Mobile Start, SAP processes your Personal Data if and to the extent

• in accordance with your consent for this specific purpose,
• necessary to fulfill legal requirements applicable to SAP.

Undesirable Consequences and Damages

SAP implements safeguards intended to help protect the fundamental rights of everyone whose Personal Data is processed by SAP, whether they are customers, suppliers, partners, prospects, employees, or applicants. As with all data processing activities, there exists the possibility of associated risks including but not limited to accidental or unlawful destruction, loss, alteration, or unauthorized disclosure. By using Our services, you acknowledge and accept the possible inherent risks associated with such processing.

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 SAP Mobile Start 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 Sensitive 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 are obliged to provide Personal Data to SAP and you fail to provide such Personal Data, kindly note that SAP may not be able to provide you with the respective service and/or business relationship.

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

• your employer in the context of its business relationship with SAP and/or the SAP Group,
• Third Parties you directed to share your Personal Data with SAP.

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:

• for SAP to comply with statutory obligations to retain Personal Data, resulting inter alia e.g. from applicable export, finance, tax or commercial laws.

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

Your Personal Data is stored inside OR outside Vietnam, however your Personal Data may be processed globally. With your consent, Your Personal Data will be transferred to or accessed by the following categories of third parties to process your Personal Data:

• SAP Group entities: Other entities of the SAP Group may also receive or gain access to Personal Data either when rendering group internal services centrally and on behalf of SAP SE and the other SAP group entities or when Personal Data is transferred to them on a respective legal basis. In these cases, these entities may process the Personal Data for the same purposes and under the same conditions as outlined in this Privacy Statement. The current list of SAP Group entities can be found here.

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:

• access your Personal Data that we have on you, or have it updated.
• Obtain a copy of the Personal Data you provided to SAP, if SAP uses your Personal Data based on your consent or to perform a contract with you. In this case, please contact sapmobilestart@sap.com and specify the information or processing activities to which your request relates, the format in which you would like to receive the Personal Data, and whether it should be sent to you or another recipient. SAP will carefully consider your request and discuss with you how it can best be fulfilled.
• Delete your Personal Data we hold about you. Please note, however, that SAP can or will delete your Personal Data only if there is no statutory obligation or prevailing right of SAP to retain it. If you request from SAP to delete your Personal Data, you may not be able to continue to use any SAP service that requires SAP's use of your Personal Data.
• Right to object against SAP further processing your Personal Data, if and to the extent SAP is processing your Personal Data based on its Legitimate Interest. When you object to SAP's processing of your Personal Data, SAP will carefully review your objection and cease further use of the relevant information, subject to SAP's compelling legitimate grounds for continued use of the Personal Data, which may override your interest in objecting, or if SAP requires the information for the establishment, exercise, or defense of legal claims.
• Right to object to direct marketing or to apply profiling in relation to direct marketing. When you object to SAP's processing of your Personal Data for direct marketing purposes, SAP will immediately cease to process your personal data for such purposes.
• Revoke consent, wherever SAP is processing your Personal Data based on your consent, you may at any time withdraw your consent by unsubscribing or giving Us respective notice of withdrawal. In case of withdrawal, SAP will not process Personal Data subject to this consent any longer unless legally required or permitted to do so (e.g. if your Personal Data is needed by SAP do assert or defend against legal claims). In case SAP is required or permitted to retain your Personal Data for other legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law or fulfil the other purpose. However, any withdrawal has no effect on past processing of Personal Data by SAP up to the point in time of your withdrawal. Furthermore, if your use of an SAP offering requires your prior consent, SAP will no longer be able to provide the relevant service, offer or event to you after your revocation.
• Lodge a complaint with Vietnam's Ministry of Public Security as prescribed by law.
• Claim damage if there are proven violations against regulations on protection of your personal data subject, unless otherwise agreed upon or unless otherwise prescribed by law.
• Self-protection according to relevant laws or request competent agencies and organizations to implement civil right protection methods according to applicable regulations.

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 sapmobilestart@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, SAP Mobile Start 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 SAP Mobile Start.

Per applicable Vietnamese privacy laws and subject to the lawful exceptions, the processing of Personal Data of a child is subject to his/her consent if he/she is seven (7) years old or above and the consent of his/her parent or guardian.

The processing of the child’s Personal Data will be stopped and permanently deleted or destroyed in the following cases:

1. The Personal Data is processed for unintended purposes or the processing purposes have been accomplished under the consent of the data subject, unless otherwise provided for by law;
2. The child's parent or guardian withdraws the consent to the processing of the child's Personal Data, unless otherwise provided for by law;
3. There are sufficient grounds to prove that the processing of the child's Personal Data affects legitimate rights and interests of the child at the request of the competent authority, unless otherwise provided for by law;