Privacy Statement

This Privacy Statement was updated on August 17, 2020.

A. General Information

When does this Privacy Statement apply?  

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.

Who is the Data Controller?

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 privacy@delighted.com. 

What Personal Data does Delighted collect?

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. 

Why does Delighted need your Personal Data?

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.  

From what types of third parties does Delighted obtain Personal Data?

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).

How long will Delighted store my Personal Data?

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.  

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

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 privacy@delighted.com. 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/.

Delighted complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the United Kingdom, and Switzerland to the United States, respectively, including the onward transfer liability provisions. Delighted has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

The key goals of Privacy Shield are to inform both EU and Swiss individuals about:

• the right of individuals to access their personal data
• the choices and means an organization offers individuals for limiting the use and disclosure of their personal data
• the requirement for an organization to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

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: privacy@delighted.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:

What are your data protection rights?

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:

• to request from Delighted access to your Personal Data that Delighted collects, uses, discloses, or sells (if applicable) about you;
• to request that Delighted deletes Personal Data about you; 
• to opt-out of the sale of Personal Data, if applicable;
• to non-discriminatory treatment for exercise of any of your data protection rights;
• in case of request from Delighted for access to your Personal Data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance.  

How can you exercise your data protection rights?

Please direct any requests to exercise your rights to privacy@delighted.com, 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.

How will Delighted verify requests to exercise data protection rights?

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. 

B. Processing based on a statutory permission

Why does Delighted need to use my Personal Data and on what legal basis is Delighted using it?

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:

• Fraud and Legal Claims. If required, Delighted will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
• Questionnaires and surveys. Delighted could 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 data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, Delighted will use this personal data to improve its products and services.
• Contract performance. If you purchase or intend to purchase goods or services from Delighted on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a “Customer Contact”) and Delighted, Delighted will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs Delighted that you are his replacement, Delighted will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
• Creation of anonymized data sets. Delighted will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
• Personalized Newsletter. If you opt-in to receive marketing communications such as newsletters from Delighted, Delighted will collect and store details of how you interact with the newsletters to help create, develop, operate, deliver and improve our newsletter communications with you. This information is aggregated and used to help Delighted provide more useful information and to understand what is of most interest.
• Recordings for quality improvement purposes. In case of telephone calls or chat sessions, Delighted will record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of Delighted services.
• To keep you up-to-date or request feedback. Within an existing business relationship between you and Delighted, Delighted might inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from Delighted. Furthermore, where you have attended a webinar, seminar or event of Delighted or purchased products or services from Delighted, Delighted might contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.

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 privacy@delighted.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:

• To plan and host events
• To host online forums or webinars
• For marketing purposes such as to keep you updated on Delighted’ latest products and services and upcoming events
• To contact you to discuss further your interest in Delighted services and offerings
• To help Delighted create, develop, operate, deliver and improve Delighted services, products, content and advertising and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Delighted
• To provide more personalized information to you
• For loss prevention
• For account and network security purposes
• For internal purposes such as auditing, analysis, and research to improve Delighted’ products or services
• To verify your identity and determine appropriate services
• To assert or defend against legal claims
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity
• To debug to identify and repair errors that impair existing intended functionality
• Short-term, transient use, provided the personal information is not disclosed to a third party and is not used to build a profile about you or otherwise alter your individual experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Delighted.

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.  

C. Processing based on consent.

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.

Delighted events.   

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 privacy@delighted.com. 

D. Cookies and similar tools  

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.

Cookies may be used to deliver customized content to website visitors. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Required Cookies. These cookies are required to enable core site functionality.
• Functional Cookies. These cookies allow us to analyse site usage so we can measure and improve performance.
• Targeting cookies. These cookies are used by advertising companies to serve ads that are relevant to your interests.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.