This Privacy Statement was updated on August 17, 2020.
This Privacy Statement applies to information that can be used to identify you (“Personal Data”) and that you provide to Delighted or which is derived from the Personal Data as outlined below.
The data controller of www.delighted.com is Delighted LLC, 333 W. River Park Drive, Provo, UT 84604, United States of America (“Delighted”). Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection but it is in any case displayed on the individual registration form’s privacy statement. Delighted’s data protection officer can be reached at email@example.com.
In the normal course of business, Delighted collects Personal Data such as contact information (e.g., name, address, phone number, email address, and your employer) and payment details for customers.
Delighted requires your Personal Data to provide you with access to Delighted’s services, to comply with contractual and statutory obligations, including checks required by applicable export laws and to stay in touch with you. Although providing your Personal Data is voluntary, without your Personal Data, Delighted cannot provide you with access to its services.
In most cases Delighted collects Personal Data from you. Delighted might also obtain Personal Data from third parties, if the applicable national law allows Delighted to do so. Delighted will treat this Personal Data according to this Privacy Statement, plus any additional restrictions imposed by the third party that provided Delighted with it or the applicable national law. These third-party sources include Delighted or the SAP Group’s business dealings with your employer (for details, please see “Contract Performance” subsection of Section B below) or third parties you directed to share your Personal Data with Delighted (e.g. in case of an event where you permit the host of the event to share your registration data with Delighted).
Delighted will only store your Personal Data for as long as it is required for the performance of contractual obligations, to make its services available to you, for Delighted to comply with its statutory obligations resulting from applicable export laws, and to fulfill the purposes outlined in this Privacy Statement.
Delighted will also retain your Personal Data for additional periods if applicable laws require it.
Your personal data will be passed on to the following categories of third parties for processing: companies within the SAP group; vicarious agents (e.g., third party service providers for consulting services and other additional related services); other services providers (e.g. for the provision of the website); state agencies and bodies if required by law.
As part of a global group of companies operating internationally, Delighted has affiliates (the “SAP Group”) and third-party service providers outside of the European Economic Area (the “EEA”) and will transfer your Personal Data to countries outside the EA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, Delighted uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy of such standard contractual clauses by sending a request to firstname.lastname@example.org. You can also obtain more information from the European Commission on the international dimension of data protection here.
Delighted also bases transfers of Personal Data to the US on the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. For details about the Privacy Shield program, please visit https://www.privacyshield.gov/.
The key goals of Privacy Shield are to inform both EU and Swiss individuals about:
Delighted’ Privacy Shield self-certification does not cover human resources data.
Privacy Shield may provide individuals the right to (i) access the data that we hold about them, (ii) request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield, or (iii) limit the use and disclosure of their personal information. In compliance with the Privacy Shield Principles, Delighted commits to resolve complaints about our collection or use of personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Delighted at: email@example.com.
Delighted has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (AAA), an alternative dispute resolution provider located in the United States. If an individual does not receive timely acknowledgment of its complaint from us, or if we have not addressed an individual’s complaint satisfactorily, such individual should contact the AAA for more information or to file a complaint (contact details below). The services of the AAA are provided at no cost.
Because adequate protection is provided by Privacy Shield participants, contracts with Privacy Shield participants for mere processing do not require prior authorization (or such authorization will be granted automatically by the EU Member States), as would be required for contracts with recipients not participating in the Privacy Shield or otherwise not providing adequate protection.Delighted self-certifies with Privacy Shield. A self-assessment is signed by a company officer or other authorized representative of the organization at least once a year and made available upon request by individuals or in the context of an investigation or a complaint about non-compliance. Delighted is required to respond promptly to EU or Swiss individual inquiries, and other requests for information from the Department of Commerce relating to its adherence to the Privacy Shield Principles.
Under Privacy Shield, an individual has the right, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Under Privacy Shield, Delighted must respond to individual complaints within 45 days. For additional information, visit here.
Delighted’ Independent Dispute Resolution (IDR) Provider is:American Arbitration Association
You can request from Delighted access at any time to information about which Personal Data Delighted processes about you and the correction or deletion of such Personal Data. Please note, however, that Delighted can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Delighted to retain it. Kindly note further that if you request that Delighted deletes your Personal Data, you will not be able to continue to use any Delighted service that requires Delighted’ use of your Personal Data.
If Delighted uses your Personal Data based on your consent or to perform a contract with you, you can further request from Delighted a copy of the Personal Data that you have provided to Delighted. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. Delighted will carefully consider your request and discuss with you how it can best fulfill it.
Furthermore, you can request from Delighted that Delighted restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Delighted has about you is incorrect, subject to the time Delighted requires to check the accuracy of the relevant Personal Data; (ii) there is no legal basis for Delighted processing your Personal Data and you demand that Delighted restricts your Personal Data from further processing; (iii) Delighted no longer requires your Personal Data but you state that you require Delighted 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 Delighted based on Delighted legitimate interest (as further set out below), subject to the time required for Delighted to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.
For individuals within the State of California, you instead have the right:
Please direct any requests to exercise your rights to firstname.lastname@example.org, or, if you are located in the State of California, you can also call toll-free using the numbers provided here. You can also designate another person to submit requests to exercise your data protection rights to Delighted. You can give authorization to such person by granting them a limited power of attorney to exercise your data protection rights on your behalf.
Delighted will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, Delighted will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by Delighted. This could include matching two or more data points that are already maintained by us.
In accordance with the verification process set forth in the California Consumer Privacy Act (“CCPA”), Delighted will require a more stringent verification process for deletion requests, or for Personal Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data. If Delighted must request additional information from you outside of information that is already maintained by Delighted, Delighted will only use it for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.
Delighted will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.
If you take the view that Delighted is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live.
Providing the requested services. Delighted requires your Personal Data to deliver services you order under a contract Delighted has with you, to establish a contract for goods or services between you and Delighted, and to send you invoices for ordered services. Delighted processes Personal Data to fulfill contractual obligations pursuant to Article 6(1), Subparagraph 1(b) GDPR or the equivalent article under other national laws, when applicable.
Ensuring compliance. Delighted and its products, technologies, and services are subject to the export laws, trade sanctions, and embargoes (“Export Laws”) of various countries including, without limitation, those of the European Union (“EU”), Germany and of the United States of America. Therefore, You acknowledge that, pursuant to the applicable Export Laws issued by these countries, Delighted is required to:
(a) take measures to prevent persons, entities and organizations listed on government-issued sanctioned party lists from accessing certain products, technologies, and services through Delighted’s websites or other delivery channels controlled by Delighted. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Delighted’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match; and
(b) ensure that no individuals from embargoed countries access its services. Therefore, when an existing user logs into a website, app or cloud service of Delighted from an embargoed country, the user’s registration data and IP address may be used by Delighted to block the user’s access and to log access attempts from embargoed countries.
Any such usage of registration data and IP addresses by Delighted is necessary for Delighted’ compliance with applicable EU Export Laws (Article 6 para. 1 (c) GDPR) and Delighted’s legitimate interest to comply with non-EU Export Laws (Article 6 para. 1 (f) GDPR) or the equivalent article under other national laws, when applicable).
Delighted legitimate interest. Delighted can use your Personal Data based on its legitimate interest (Article 6 para. 1 lit. f GDPR) as follows:
You can at any time object to Delighted’s use of your Personal Data as set forth in this section by sending an email to email@example.com. In this case, Delighted will carefully review your objection and cease further use of the relevant information, subject to Delighted’ compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if Delighted requires the information for the establishment, exercise or defense of legal claims.
Processing under applicable national laws. If the applicable national law allows Delighted to do so, Delighted will use information about you for a business purpose, some of which is Personal Data:
In accordance with the disclosure requirements under the CCPA, Delighted is exempt from providing a notice to opt-out because it does not and will not sell your Personal Data.
In the following cases, Delighted will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6 para. 1 lit. a GDPR or the equivalent article under other national laws, when applicable).
Children. This offering 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, you cannot register with and use this offering.
U.S. Children’s Privacy. Delighted does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe that Delighted collected information about a child, please contact Delighted as described in this Privacy Statement. Delighted will take steps to delete the information as soon as possible. Given that Delighted services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, Delighted does not sell the Personal Data of any minors under 16 years of age.
Marketing. Delighted requires your Personal Data to inform you about Delighted’ latest products, service offers and events. Any such use of information is based on the consent you grant hereunder. Delighted will use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Delighted (prior purchases, participation in webinars, seminars or events or the use of (web) services in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about SAP’s software and services (including marketing-related newsletters) as well as events of SAP and in order to display relevant content on Delighted websites. In connection with these marketing-related activities, Delighted will 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.
Forwarding your Personal Data within the SAP Group. Delighted will transfer your Personal Data to other affiliated companies within SAP's Group of undertakings for the purpose to inform you about their latest products, service offers and events in the same way Delighted does under this Privacy Statement. A list of entities in the SAP Group can be found here. In such cases, the SAP Group will use the Personal Data for the same purposes and under the same conditions as set forth in this Privacy Statement.
Social media features. Delighted offers social network functionality in various parts of our website and on apps. We give you the opportunity to share and recommend your content in social networks in our online offerings. If you visit our website and use the recommendation features, we pass on the URL to the social network you select where your Personal Data will be then used by the social network according to the social network’s own privacy statement. We recommend that you read the privacy statement of the respective social networks carefully.
Profiles. Delighted offers you the option to use services, including to view tutorials or take trainings, that require you to register and allow you to create a user profile. User profiles provide the option to display personal information about you, including but not limited to your name, photo, address, email, telephone number, personal interests, skills, etc. Profile data is processed to personalize the interaction with other users to foster the quality of communication and collaboration via such services. Profile data might also be shared with other web offerings and services across the SAP Group, including Ariba, Concur, Hybris, etc. (SAP Cloud ID). The provision of any such information about you as well as the decision to share information with other services is at your free will and based on the consent that you grant.
Event profiling. If you register for an event, seminar, or webinar of Delighted, Delighted shares basic registration information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.
Tracking during an event. Delighted requires your Personal Data including any occasion where you allowed your event badge to be scanned, to evaluate behavioral aspects by means of tracking during the relevant event. Delighted might process tracking data in the context of Delighted events for purposes of tracking attendance, determine the attendees’ interests in certain topics and identify drivers for the attendees’ satisfaction and dissatisfaction to optimize planning and investments for future events. Any such use of information is based on the consent you grant.
Processing Special Categories of Personal Data. When you register for or request access to an event or seminar, Delighted may ask whether you require any accommodations because of your health or dietary restrictions. Any such use of information is based on the consent you grant. Kindly note that if you do not provide Delighted with information regarding what accommodations you require, Delighted will not be able to accommodate for it.
Photograph before or during the event. You may be asked to provide Delighted with your current photograph via e-mail or Delighted could ask to take a picture of you when you arrive at the event. By sending Delighted your photograph or allowing a photo of you to be taken, you acknowledge that Delighted will use your picture for the purposes described in this Privacy Statement.
Withdrawal of consent. You may withdraw your consent for Delighted to process your Personal Data as stated in this Privacy Statement at any time. Once you assert this right, Delighted will not process your Personal Data any longer unless legally required to do so. However, any withdrawal has no effect on past processing by Delighted up to the point in time of your withdrawal. Please direct any such request to firstname.lastname@example.org.
For the https://delighted.com/ site, Delighted collects and analyzes aggregate visitor information, including the domain name, visited surveys, referring URLs, and other publicly available information. We use this information to improve our website and services and to customize the content of our pages for each website visitor.
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