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Concur Technologies (en) - Política de Privacidad y Puerto Seguro 12-may-2018 | 100%
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# Antigua Versión Nueva Versión
0 Concur Privacy Policy
1 NOTICE OF CHANGES to Concur.com visitors: Concur has made changes to its privacy policy in order to update the information on how to contact its U.S.-based third party dispute resolution provider and inform visitors about its recourse to a cross-Device Tracking Technology. You may contact us at privacy-request@concur.com with any questions or concerns about this Privacy Policy and any changes thereof.
2 Last Updated: October 6, 2017
3 This Privacy Policy (“Policy”) summarizes the various ways that Concur Technologies, Inc. and Concur Holdings (Netherlands) B.V. (as applicable) and their subsidiaries, and other affiliated and related companies ("Concur" or "we" or “us”) use the information you provide to us or we gather from you while you access or use the Web sites of Concur, including concur.com (collectively, "Sites") our mobile applications (“App”), and our related sites and online services (collectively, the “Services”), however accessed and/or used, whether via personal computers, mobile devices or otherwise ("Device"). It is our goal to provide you with information that is tailored to your individual needs and, at the same time, protect and respect your privacy.
4 Please read this Policy carefully. Your access to or use of any part of the Services will constitute your notice about our collection, use, and disclosure of your information in accordance with this Policy. If you do not wish for us to collect, use, and disclose your information in accordance with this Policy, please do not access or use the Services. This Policy does not cover information collected elsewhere, including, without limitation, offline or on sites linked to through the Services. We may add to or amend this Policy with other notices. We may also post different privacy statements for some Services and when we do so, this Policy does not apply.
5 This Policy applies solely to information collected by us through the Services and does not apply to any third-party activities, including third party websites linked from our Services, third party social networking platforms or features we make available through our Services, or third-party ads displayed on our Services. We are not responsible for the privacy practices or content of such third-parties. We encourage you to read the privacy statements of those third parties.
6 INFORMATION COLLECTED
7 We collect information from you in various ways when you use our Sites. We collect information you directly provide to us. For example, we collect your name, home location, billing or mailing address, email address, postal address, phone number, fax number, demographics, preference information and other information you provide us on our Sites. We also collect credit card numbers if you purchase services on our Sites or use services that reconcile your credit card charges. We may also obtain information from other sources and combine that with information we collect on our Sites.
8 When you visit our Sites, some information is automatically collected. For example, when you visit our Sites, your computer's operating system, Internet Protocol (IP) address, Device Identifier, access times, browser type, device type, domain name, access times, duration of visit, referring URL, platform, new and repeat information, time stamp and language, and referring Web site addresses are logged automatically. We also collect information about your usage and activity on our Sites. A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and allows us to identify your Device by its Device Identifier.
9 Tracking Technologies. We may use various technologies to automatically collect Device Identifiers, and other information about you ("Tracking Technologies"). These Tracking Technologies work in different ways, for example some may be downloaded to your Device and others may set or modify settings on your Device. The following are examples of a few of the methods that may be used to collect information include, without limitation, the following (and subsequent technology and methods hereafter developed):
10 Cookies. We may automatically collect information using "cookies." Cookies are small data files stored on your hard drive by a Web site. Among other things, cookies help us improve our Sites and your experience. We use cookies to see which areas and features are popular and to count visits to our Sites. If you set your browser not to accept cookies or if you reject a cookie (your help screen or manual should tell you how to do this), it may affect certain features or services of our Sites.
11 Web Beacons. We may collect information using Web beacons. Web beacons are electronic images that may be used on our Sites 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.
12 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.
13 Location-identifying Technologies. Additionally, the Services may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the Services. Upon downloading the App, we determine your approximate and/or exact location information to provide location-based services. In addition to traditional GPS location-based services, some of the retailers and others we work with may install other types of location tracking technology, such as low power Bluetooth, wifi, radio transmitters, or other devices in physical locations. These technologies emit a signal that the App can detect to pinpoint your proximity to those locations (such as how close you are to security checkpoints, gates, terminals, or retail locations and products) or otherwise interact with the App (such as to send you helpful information, offers, and discounts). To learn more about iBeacons visit Apple’s privacy policy and website.
14 Targeting‑Related We may use Tracking Technologies to learn more about you and your preferences and deliver content, including ads that seem relevant to your interests on our Services and third‑party services, based on how you interact with advertisements or content, and/or based on your location and other information about you.
15 Flash LSOs. When we post videos or other media on our blog, 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. To learn how to manage privacy and storage settings for Flash cookies click here:
16 http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118
17 Third Party Advertisements. We and our third party partners may use information collected using third-party cookies and Web beacons on our Services and in our emails to deliver ads about our Services displayed to you on third-party websites and applications. We also may use cookie information and other methods to know when you return to our Services after visiting these third-party websites and applications. We use this and other information about you 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 as described above. We may use third parties to serve ads in our Services. These third parties may automatically collect information about your use of the Service, visits to our Site and other Web sites, your IP address, your ISP, the browser you use to visit our Site (but not your name, address, email address or telephone number). They do this using cookies, clear gifs or other 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 Site and the other sites tracked by these third parties. This Policy does not apply to, and we are not responsible for, cookies or clear gifs 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 cookies and other technology. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.networkadvertising.org/consumer/opt_out.asp .
18 Adobe Marketing Cloud Device Co-Op. We have enabled the Adobe Marketing Cloud Device Co-Op Tracking Technology. It is in essence a cross-Device Tracking Technology to help us better understand how you use certain Sites and Apps of ours across the various Devices you use, and to deliver tailored promotions.
19 Learn more about how Adobe does this: https://cross-device-privacy.adobe.com/?d_rd=1&d_mid=34161404856489225982552197159114168424&d_orgid=9E1005A551ED61CA0A490D45@AdobeOrg#learn_more_start_surfing
20 Learn more about how you may opt-out of this program: https://cross-device-privacy.adobe.com/?d_rd=1&d_mid=34161404856489225982552197159114168424&d_orgid=9E1005A551ED61CA0A490D45@AdobeOrg
21 USE OF PERSONAL INFORMATION WE COLLECT
22 We use personal information collected through our Sites for purposes described in this Policy or disclosed to you on our Sites or in connection with our services. For example, we may use your information to:
23 operate and improve our Sites and services;
24 personalize and customize your Site experience, content, marketing, and recommendations across all our Services, including to target content on our Services to more closely match your interests or your location;
25 process and deliver contest entries and rewards;
26 respond to your comments and questions and provide customer service;
27 provide and deliver products and to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
28 register you for events and training;
29 send you information related to your requests and purchases, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
30 communicate with you about new contests, promotions and rewards, upcoming events, and other news about products and services offered by Concur and our selected partners;
31 link or combine with other personal information we get from third parties, to help understand your needs and provide you with better service.
32 Concur may store and process personal information in the United States and other countries.
33 SHARING OF PERSONAL INFORMATION
34 When you use the Service, your personal information and your travel information will be shared with the third parties you designate for access to such information including other companies, websites, mobile applications, your friends, relatives, and business associates. Depending upon the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change these settings as to who has access to your information by going to your account settings and then changing your publishing options.
35 You may choose to display certain information you give us in your public profile. Our Site also offers publicly accessible blogs or community forums. You should be aware that any information you choose to share in these areas may be read, collected, and used by others. In addition, you may be able to send your location information via the Services to other Services users. You should consider the pros and cons involved in disclosing your location information to us and to other people. Where a user of the Services requests that their location information be revealed to other persons, the user will be provided options for managing sharing services, which may be through third party services such as through Twitter and Facebook. We are not responsible for the acts, omissions or policies of such third parties.
36 In general, most of your travel related information, such as upcoming destinations and travel statistics, is displayed only to other users of the Service to whom you have specifically connected as part of your Concur / TripIt network. You can change your privacy settings to designate which types of information are shared and with whom by visiting the Profile and Privacy page. You may also post information about your travel plans or current travel status through your Concur / TripIt connections or other social networking connections or otherwise instruct the Service to automatically provide such information to other users of the Service and with your social networking connections.
37 We do not share your personal information with third parties other than as follows:
38 in an aggregated form that does not directly identify you;
39 with your consent, for example, when you agree to our sharing your information with other third parties for their own marketing uses subject to their privacy policies;
40 with your employer if you are participating in a Concur service provided through your employer;
41 with third party vendors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us;
42 with third party websites, services and mobile applications you authorize to link to your Concur service as part of their service to you;
43 to (i) comply with laws or to respond to lawful requests and legal process, (ii) to investigate, prevent, or take action regarding illegal or suspected illegal activities, (iii) to protect the rights and property of Concur our agents, members, and others including to enforce our agreements, policies and terms of use or (iv) in an emergency to protect the personal safety of Concur, its customers, or any person;
44 in connection with a corporate transaction, such as a divestiture, merger, consolidation, sale of company assets, financing or acquisition of all or a portion of our business to another company.
45 from time to time, we also may share general information about our Services, users, and visitors such as the number of visitors, aggregate and/or non-personally identifiable demographic and travel data, etc., with third parties (including with your employer if your account was provided through your employer).
46 SECURITY OF YOUR PERSONAL INFORMATION
47 We maintain data handling and storage practices and procedures that are designed to promote the integrity and confidentiality of the personally identifiable information. No method of transmission over the Internet or method of electronic storage is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction, we cannot guarantee its absolute security.
48 INTERNATIONAL TRANSFER OF YOUR PERSONAL INFORMATION
49 The Internet is a global environment and Concur is a global corporation operating in many countries around the world. Collecting and processing your information using the Internet necessarily involves the transmission and storage of personal information on an international basis and when Concur transfers your personal information across national borders, we do so in compliance with applicable law and the practices we have developed to ensure the integrity and confidentiality of the personally identifiable information we process.
50 Pursuant to the European Court of Justice ruling dated October 6, 2015 which invalidated the ability of European companies to rely on the Safe Harbor Framework for cross border data transfers, and in an effort to meet the “adequacy requirements” under EU data protection laws, the Concur affiliates have entered into and executed an Intra-Group Data Protection Agreement with SAP SE, as the ultimate parent company of Concur, which covers the processing and the transfer of your personal information from the European Economic Area and which incorporates the Standard Contractual Clauses to provide a mechanism approved by the European Commission as offering adequate protection when transferring personal information from the European Economic Area under the EU Data Protection Directive 95/46/EC.
51 Where Concur has entered into a business agreement for the use of Concur’s services to its business customers that involves the transfer of personal data, then, as applicable, Concur may enter into appropriate contractual clauses, including, without limitation, Standard Contractual Clauses where the transfer is required by a Concur business customer located in the European Economic Area to a country outside of the European Economic Area which does not meet the adequacy standard.
52 YOUR INFORMATION CHOICES AND CHANGES
53 We think that you benefit from a more personalized experience when we know more about you and your Concur experiences. The nature of our Services depends upon the use of Tracking Technologies for the purposes described above and we require your consent to such uses in order to use the Services, except that you have the option to change settings on your device and uninstall the Apps. We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed. In some cases you can limit the information you provide to us, and you can limit the communications that we send to you. You may opt out of receiving promotional emails from Concur by following the instructions in those emails. If you are registered on any of our Sites, you may login and make certain changes to your information in your account. You may also send requests about your preferences and changes to your information by emailing privacy-request@concur.com . If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. Additionally, if you are participating in a Concur service through your employer, your employer may make changes to information on your behalf. If you wish to cancel your account, modify your information, or request that we no longer use your information to provide you the Service, contact us at privacy-request@concur.com .
54 Email Choices. You can manage your email preferences by updating your profile settings. 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 may update your email preferences from time to time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your use of the Service. For example, even if you have unsubscribed from our email messages, we will still send you emails confirming emails relating directly to an itinerary or travel profile created through the Service confirming registration.
55 SMS Choices. You may manage the SMS alerts regarding flight delays, gate changes, and other alert information specific to your itinerary sent by the Service to your mobile device by following the opt-out instructions in each SMS message.
56 Do Not Track. 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 personally identifiable information as described in this Policy. Many Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site including certain opt-out cookies. Cookie management tools provided by your browser usually will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118 (or in the EU http://www.youronlinechoices.com/ ).
57 We encourage you to review the privacy policies of our third party advertisers and analytics service providers ( http://preferences-mgr.truste.com/ ) to learn about your choices about information they collect from you. 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 .
58 Further, third parties may associate Tracking Technologies with our Service and in physical locations that enable the interaction with App when your Device is close. We may not control those Tracking Technologies and in such event, we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties except as explicitly stated (e.g., your consent).
59 CHANGES TO THIS POLICY
60 Concur may change this Policy from time to time without notice to you other than posting the revised policy on our Services. If we make any changes to this Policy, we will change the "Last Updated" date above. Any changes will be effective immediately upon the posting of the revised Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, Concur will not use your previously collected personal information in a manner materially different than what was stated at the time it was collected without your consent.
61 ENFORCEMENT
62 If you have any questions about this Policy or to file any complaint regarding this Policy, please contact us at the following address:
63 Concur Technologies, Inc.
64 601 – 108th Avenue NE, Suite 1000
65 Bellevue, WA 98004
66 USA
67 Attention: privacy-request@concur.com
68 Telephone: (888) 883-8411
69 Concur will investigate and attempt to resolve complaints and disputes regarding the collection, use, and disclosure of personal information by referencing the privacy principles stated in this Policy. 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 https://feedback-form.truste.com/watchdog/request .
70
71 Last Updated: May 11, 2018
72 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. As used in this Privacy Statement, “Personal Data” means any data collected through our Channels that can be used to 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 may also include sales and marketing activities carried out offline. 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.
73 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 your data on behalf of your Providing Entity.
74 Data Controller. The data controller is the SAP Concur legal entity which initially collects your information and decides how and why to use the data for its business purposes. Where a registration form is presented on an SAP Concur website, the named data controller may vary depending on the actual offering or the purpose of the data collection. For other SAP Concur websites, the data controller is the SAP Concur entity named in the legal disclosure page on the website, or 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.
75 Links to other websites. This Privacy Statement applies solely to information collected by us through the Channels and does not apply to any third-party activities, including third party websites linked from our Channels, third party social networking platforms or features we make available through our Channels, or third-party ads displayed on our Channels. We are not responsible for the privacy practices or content of such third parties. We encourage you to read the privacy statements of those third parties.
76 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
77 DATA PROTECTION OFFICER
78 SAP’s Data Protection Officer (DPO) is Mathias Cellarius, SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany, who may be contacted at Privacy@Concur.com ; or you may contact our group Privacy Team at any time at Privacy-Request@Concur.com .
79 WHAT INFORMATION WE AND OTHERS COLLECT FROM YOU AND HOW IT IS COLLECTED
80 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, 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.
81 Direct collection of business information and Personal Data
82 When you access, use and/or interact with us through a Channel, we directly collect information you voluntarily provide us. This includes but is not limited to the following:
83 information about you in the context of your professional activities, such as your name, and professional email addresses or telephone numbers
84 information about your company such as the name, size and location of your company and your role within the company
85 billing and transactional information when purchasing good and services on the Channels
86 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
87 Examples of direct interactions with you through the Channels where you provide us business information and Personal Data about you include the following:
88 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
89 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
90 sales inquiries which you initiate, such as through online chat, dedicated online “contact-us” link and “request a quote” forms
91 tele-sales (cold or warm calls) and information you provide during phone calls with sales representatives and tele-sales representatives
92 subscription to marketing communications and/or submission of marketing preference in the SAP Concur Preference Center
93 completion of questionnaires and surveys
94 participation in sweepstakes and contests
95 other conversation data triggered by the above direct interactions, such as follow-up calls and emails, thank-you emails, confirmation emails and the like
96 contacting customer support as part of a contractual or informational request
97 contact information gathering as part of implementation services for our products
98 Indirect collection of business information and Personal Data
99 We also obtain business information and Personal Data about you from third party sources, as permitted by applicable law, such as the following:
100 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
101 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
102 public databases or other data you may have made publicly available, such as social media posts on professional networks and social media platforms
103 information shared with us by the other entities of the SAP group (the current list of the SAP group entities can be found here )
104 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
105 Automatic collection of business information and Personal Data
106 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 phone 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, such as the following:
107 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
108 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
109 information about your use of social media features such as the Facebook “Like” button, LinkedIn, Twitter and others
110 past transactional behavior on the Channels based on your prior interactions with us
111 information obtained from third parties on your interests
112 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).
113 HOW YOUR INFORMATION IS USED AND PROCESSED
114 Legal Basis for Processing. We collect and process your Personal Data with your consent and/or as necessary 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.
115 Freely Given 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.
116 Purposes of Processing. We use and process Personal Data about you for purposes described below:
117 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 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.
118 To Ensure compliance. We use your Personal Data to prevent, detect, mitigate, and investigate fraudulent or illegal activity. The information 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.
119 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:
120 Questionnaires and surveys. We may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If Personal Data is nonetheless included in questionnaires and surveys, SAP Concur may use such Personal Data for marketing research and to improve its products and services.
121 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.
122 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.
123 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.
124 Social media channel communications. We may engage into communications with you through social media channels until you request us to not be contacted any longer.
125 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 up to date and complete or to provide a more accurate profile of you and your interests to provide you with more relevant content.
126 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.
127 To provide updates about SAP Concur’s goods and services. 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 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 for you to manage your information, your marketing preferences and exercise your opt-out choices.
128 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 Concur Digital 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, if created in the SAP Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of SAP 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 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.
129 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.
130 To 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.
131 HOW WE FOLLOW VISITS AND USAGE, WHY AND HOW YOU KEEP CONTROL (COOKIES, ANALYTICS AND ADVERTISING)
132 We may use Tracking Technologies to collect information. The following are some examples of Tracking Technologies we may use:
133 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 a cookie (your help screen or manual should tell you how to do this), it may affect certain personalization features or services of our websites.
134 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).
135 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. For more information on cookies, visit www.allaboutcookies.org.
136 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.
137 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.
138 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. To learn how to manage privacy and storage settings for Flash cookies visit www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118
139 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.
140 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.
141 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. If you would like more information about this practice and to know your choices about not having this information used by these companies, visit www.networkadvertising.org/consumer/opt_out.asp .
142 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.
143 Managing Preferences. You have the right to accept or reject cookies and can access and/or change your cookie preference or opt-out of third party analytics or opt-out of receiving interest-based advertising from SAP Concur at any time by accessing our cookie preferences page via the link on the site. If you have any problems using this mechanism, please email us at Privacy-Request@Concur.com
144 HOW YOUR INFORMATION IS SHARED
145 We work with 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.
146 As permitted under applicable law, we may transfer your Personal Data to the other entities of the SAP group. 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 .
147 As permitted under applicable law, 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). 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.
148 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. 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.
149 We may also share your information in the following circumstances:
150 in an aggregated form that does not directly identify you, such as statistical information about visitors to our Channels
151 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.
152 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
153 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, or legal process served to us
154 HOW YOUR INFORMATION IS KEPT SAFE
155 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 information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction, but we cannot guarantee its absolute security.
156 HOW YOUR INFORMATION IS TRANSFERRED INTERNATIONALLY
157 As part of a global group of companies, SAP Concur has affiliates and third-party service providers within, as well as outside of, the European Economic Area (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. 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.
158 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 .
159 HOW YOUR INFORMATION IS STORED AND RETAINED
160 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).
161 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.
162 WHAT PRIVACY CHOICES AND CHANGES ARE AVAILABLE TO YOU
163 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 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 . 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.
164 Cookies and Do Not Track. You can opt out of cookies that are not required to enable core site functionality and can manage your cookie preferences via the link on the website. 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. 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 .
165 Analytics and Advertising. We encourage you to review the privacy policies of our third-party advertisers and analytics service providers to learn about your choices about information they collect from you. Many are available at Preferences-Mgr.Truste.com or through the cookie preferences link on our website. 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.
166 YOUR EUROPEAN PRIVACY RIGHTS
167 We adhere to applicable data protection laws in the EEA, which, if applicable to you, include the rights described below. If you wish to exercise any privacy right that is available to you, we will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes and/or to complete transactions that you began prior to requesting any deletion.
168 Right not to provide consent or to withdraw consent. Where we seek to rely on your consent in order to process certain parts of your Personal Data, you have the right not to provide your consent or to withdraw your consent at any time. In case of withdrawal, SAP Concur will not process the Personal Data subject to this consent any longer unless legally required to do so. In case we are required to retain your Personal Data for legal reasons, such data will be restricted from further processing and only retained for the term required by law. Withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, if your use of a good or service requires your prior consent, we will no longer be able to provide the relevant good or service to you after withdrawal of your consent.
169 Right of Information and Access. You can require SAP Concur to confirm at any time that SAP Concur is processing your Personal Data, or to have access to the Personal Data SAP Concur may have about you. You may also request information about the purpose of the processing, the categories of Personal Data concerned, third parties that might have received the data from SAP Concur, the source of the Personal Data, if you did not provide it directly to SAP Concur, and how long it will be stored. Reasonable access to your Personal Data will be provided at no cost to you upon request. If access cannot be provided within a reasonable time frame, SAP Concur will provide you with a date when the information will be provided. If for some reason access is denied, SAP Concur will provide an explanation as to why access has been denied.
170 Right to Rectification. You have a right to correct the record of your Personal Data maintained by SAP Concur if it is inaccurate.
171 Right of Erasure. In certain circumstances, you may have the right to the erasure of Personal Data that we hold about you, such as it is no longer necessary for the purposes for which it was originally collected.
172 Right to Data Portability. If SAP Concur uses your Personal Data on the legal basis of either your consent or performance of a contract with you, you may also request from SAP Concur a copy of the Personal Data you provided to us, clearly stating which Personal Data you require from SAP Concur in which format and whether the Personal Data shall be provided to you or another recipient. We will carefully review your request and discuss with you how it can be best implemented.
173 Right to Restriction of Processing. 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, (but only for as long as we are required to check the accuracy of the relevant Personal Data), (ii) there is no legal basis for us processing your Personal Data and you demand that we restrict your Personal Data from further processing, (iii) we no longer require your Personal Data but you claim that you require us 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 us, where based on our legitimate interest, for as long as it is required to review as to whether we have a prevailing interest or legal obligation in processing your Personal Data.
174 Right to Object to Processing based on Legitimate Interest. Where we rely on our legitimate interest to process certain parts of your Personal Data, you have the right to object to such processing at any time. If you do so, we will cease using your Personal Data and remove it from our systems unless such Personal Data is permitted to be used by SAP Concur for another purpose set out in this Privacy Policy or we determine and demonstrate a compelling legitimate interest to continue in processing your Personal Data.
175 Other rights. As applicable under French law, you can also send us specific instructions regarding the use of your Personal Data after your death.
176 Right to lodge a complaint. If you take the view that SAP Concur is not processing your Personal Data in accordance with the requirements set out in the Privacy Statement or applicable EEA data protection laws if such laws apply to you, 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 the SAP Concur controller that collected your Personal Data has its registered seat. A list of the national data protection authorities can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 .
177 If you would like to exercise any of the above rights, please contact Privacy-Request@Concur.com so that we may consider your request under applicable law, verify any relevant legal requirements and exemptions, including steps to verify your identity before complying with the request.
178 CHANGES TO THIS PRIVACY POLICY
179 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.
180 QUESTIONS
181 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:
182 Concur Technologies, Inc.
183 601 – 108th Avenue NE, Suite 1000
184 Bellevue, WA 98004
185 USA
186 Attention: Privacy Manager
187 Telephone: (888) 883-8411
188 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 .