SAP NS2 Privacy Statement
Last Updated: October 2024
INTRODUCTION AND OVERVIEW
SAP National Security Services, Inc. (“SAP NS2”, “we”, “us” or “our”) respects the privacy of the visitors to our digital properties and the government agency and corporate users of our products and services, and we are committed to protecting it through our compliance with this privacy statement (“Privacy Statement”).
This Privacy Statement describes how SAP NS2 collects, stores, uses, and safeguards your Personal Data when you use our website at https://www.sapns2.com/ (the “Site”), our mobile/tablet applications (“Apps”), and through any other websites, pages, features, or content owned and operated by SAP NS2 that direct to this Privacy Statement (collectively, including the Site and Apps, the “Services”). “Personal Data” (used interchangeably in this Privacy Statement with the term “personal information”) means any information that relates to an identified or identifiable individual and can include information about how you engage with our Services (see Section 3 for categories of Personal Data SAP NS2 collects).
By using our Services, you acknowledge that we will collect and process your personal information in accordance with this Privacy Statement and our Terms of Use. If you do not feel comfortable with any part of this Privacy Statement or our Terms, please discontinue use of the Services or engaging with SAP NS2 immediately.
CONTENTS
- UPDATES TO THIS PRIVACY STATEMENT
- WHO DO WE MEAN WHEN WE SAY SAP NS2 IN THIS PRIVACY STATEMENT
- WHAT CATEGORIES OF PERSONAL DATA DOES SAP NS2 COLLECT?
- FOR WHAT PURPOSES DO WE PROCESS YOUR DATA
- HOW LONG DOES SAP NS2 STORE YOUR PERSONAL DATA
- WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?
- WHAT ARE YOUR DATA PROTECTION RIGHTS?
- HOW CAN YOU EXERCISE YOUR DATA PROTECTION RIGHTS?
- CAN YOU USE SAP NS2’S SERVICES IF YOU ARE A MINOR?
- COOKIES AND OTHER TRACKING TECHNOLOGIES
- DATA SECURITY
- SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
- CONTACT US
UPDATES TO THIS PRIVACY STATEMENT
We may update this Privacy Statement from time to time to reflect changes in the law or as we update or expand our Services. When we make a change, we will provide you with notice by revising the “Last Updated” date at the top of this Statement. All changes will be effective as of the “Last Updated” date. Where there is a material change to our data collection and use practices, we will notify you via email of the updates. We encourage you to look for updates and changes to this Privacy Statement by checking this page when you access our Services. If you have any questions about this Privacy Statement, please reach out to us at privacy@sapns2.com, or as described in the contact information included within the “Contact Us” section below.
WHO DO WE MEAN WHEN WE SAY SAP NS2 IN THIS PRIVACY STATEMENT
The owner and operator of the Site is SAP National Security Services, Inc. 2355 Dulles Corner Blvd Suite 400, Herndon, VA 20171. SAP NS2 is also the “data controller” of personal information collected via the Site, where that term is defined under applicable local law.
Where a registration form is presented on this website, the 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.
Please note that this Privacy Statement is intended to apply to residents of the United States. If you are a resident of another country, please note that when you use our services, your personal data may be accessed or transferred outside of the jurisdiction in which you reside, including to countries that have data protection laws less protective than the laws of the jurisdiction in which you reside.
If you do not want your information transferred to, accessed, or maintained in the United States, you should immediately stop accessing or using the Services.
WHAT CATEGORIES OF PERSONAL DATA DOES SAP NS2 COLLECT?
Contact Data and Business Relationship Information
SAP NS2 collects and processes the following categories of Personal Data as contact data: e.g., first name, last name, email address, postal address/location (country, state/province, city), telephone numbers, job title, department and function, and your company’s relationship history to SAP NS2.
If you provide a credit card number or bank details to order products or services, SAP NS2 will collect this information to process your payment for the requested products or services.
Form Submissions
SAP NS2 collects and processes information that you provide by filling in forms that we make available. This includes when requesting information or assistance via our Site.
Personal Data related to statutory law or regulation
If required by statutory law or regulation, SAP NS2 may process data categories like date of birth, academic credentials, identity cards or other ID numbers, geolocation, business partner relevant information about, e.g., significant litigation or other legal proceedings, and other export control or custom compliance relevant information.
FOR WHAT PURPOSES DOES SAP NS2 PROCESS YOUR PERSONAL DATA?
To comply with statutory obligations and policies SAP NS2 processes your Personal Data for the purpose of ensuring an adequate level of technical and organizational security of SAP NS2’s products, services, online events, facilities, and premises. This may comprise the use of Personal Data for sufficient identification and authorization of designated users, internal quality control through auditing, analysis, and research, debugging to identify and repair errors that impair existing or intended functionality, account and network security, replication for loss prevention, detecting security incidents, protection against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such kind of activity.
All SAP NS2 companies operate in the United States. SAP NS2 and its products, technologies, and services are subject to export control and sanctions laws and regulations of various countries including, without limitation, the United States, Germany, and the European Union. Applicable export control and sanctions laws prohibit or restrict SAP NS2 from providing access to certain products, services, and technology by, or conducting transactions with, parties listed on government-issued restricted or denied party lists (e.g., the Bureau of Industry and Security’s Entity List, the Office of Foreign Asset Control’s Specially Designated Nationals and Blocked Persons List, the Consolidated European Union Sanctions List, etc.). SAP NS2 processes Personal Data to the extent necessary to comply with these legal requirements, our agreements, and our policies. If necessary, SAP NS2 uses Personal Data to prevent or prosecute criminal activities such as any form of cybercrime, the illegal use of Our products and services or fraud, and to assert our rights or defend SAP NS2 against legal claims.
To offer our goods and services to customers
SAP NS2 processes Personal Data in order to operate the Services and provide service to our clients. We process information you provide by filling in forms that we make available, and we maintain records and copies of your correspondence with us, if you contact us by phone or email, including for customer or technical support.
Feedback requests, questionnaires and surveys
To the extent allowed by applicable law, SAP NS2 may contact you for feedback regarding the improvement of the relevant material, product, or service. SAP NS2 may also invite you to participate in questionnaires and surveys. These will generally be designed so you can participate without having to provide information that identifies you as a participant. If you nonetheless provide your Personal Data, SAP NS2 will use it for the purpose stated in the questionnaire or survey or to improve its products and services.
To keep you up to date Within an existing business relationship between you or your employer and SAP NS2, SAP NS2 processes your Personal Data to inform you about SAP NS2 products or services which are similar or relate to products and services you or your employer have already purchased or used. SAP NS2 will inform you by email or phone about such news only as far as it is allowed by law, or if SAP NS2 has collected such information in the context of the business relationship. You are entitled to object to SAP NS2’s use for this purpose at any time by selecting the opt-out option at the bottom of each marketing related approach.
For research purposes
For research purposes and to provide anonymous reporting for internal and external clients and business partners.
To operate SAP NS2 internet pages, web-offerings, or other online events
When operating its internet pages, web-offerings or other online events (“Web-Services”), SAP NS2 processes your Personal Data for the following purposes:
Event profiling
If you register for an event, seminar, or webinar of SAP NS2, SAP NS2 may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar to promote the interaction between the participants and to stimulate the communication and the exchange of ideas.
User experience improvement SAP NS2 processes information that relates to your visit to our web offerings to improve your user experience and the display of the content on our digital properties, identify your individual demand and to personalize the way we provide you with the information you are looking for. For this purpose, we collect information regardless of whether you register with a user profile or not.
To use Cookies and similar tracking technologies
SAP NS2 processes information including Personal Data about the users of our website using cookies or similar technologies for the purposes set out in Section 10.
HOW LONG DOES SAP NS2 STORE YOUR PERSONAL DATA?
SAP NS2 only stores your Personal Data for as long as it is required:
- for the performance of the services in relation with our website;
- for SAP NS2 to comply with statutory obligations to retain Personal Data, resulting, e.g., from applicable export control, finance, tax, or commercial laws;
- to fulfill SAP NS2’s legitimate business purposes as further described in this Privacy Statement, unless you revoke consent previously granted to SAP NS2 to process your Personal Data for these purposes.
SAP NS2 may retain your Personal Data for additional periods if necessary for compliance with legal obligations to process your Personal Data or if the Personal Data is needed by SAP NS2 to assert or defend itself against legal claims. SAP NS2 will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?
Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:
Business Support Service Providers
We may employ other companies and individuals to facilitate our Services, provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Services are used. These service providers provide us support services such as credit card processing, payment gateways, subscription processing, website hosting, customer relationship management, order fulfillment and shipping, email and postal delivery, analytics, surveys, marketing services, and videoconferencing. The service providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Event Co-Sponsors and/or Pursuant to Your Consent
SAP NS2 may transfer your registration data based on your consent or as otherwise indicated by your request to companies listed on the registration page of an SAP NS2 seminar, webinar or event. For example, these companies may receive your Personal Data as co-organizer or sponsor of the event and will use your registration data for the purposes of their participation in the event. They will provide you directly with any legally required information about their processing purposes and how you may exercise your rights.
Corporate Transactions
We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your Personal Data.
As Required by Law and to Protect Lawful Interests
We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of SAP NS2 or our customers.
WHAT ARE YOUR DATA PROTECTION RIGHTS?
You can request from SAP NS2 at any time access to the Personal Data SAP NS2 processes about you and, if necessary, the correction or deletion of such Personal Data. Please note, however, that SAP NS2 can or will delete your Personal Data only if there is no statutory obligation or prevailing right/exception for SAP NS2 to retain it or otherwise not honor your request. If you request SAP NS2 to delete your Personal Data, you may not be able to continue to use any SAP NS2 service that requires SAP NS2’s use of your Personal Data.
HOW CAN YOU EXERCISE YOUR DATA PROTECTION RIGHTS?
Please direct any requests to exercise your rights to privacy@sapns2.com with the subject line “Privacy Rights Request”.
SAP NS2 will take steps to ensure it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, SAP NS2 will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by SAP NS2. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by SAP NS2.
SAP NS2 will decline to process requests that are manifestly unfounded, excessive, fraudulent, represented by third parties without duly representing respective authority or are otherwise not required by local law.
CAN YOU USE SAP NS2’S SERVICES IF YOU ARE A MINOR?
Children use of our website is limited to users over the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16 or the equivalent minimum age in the relevant jurisdiction, you cannot register with and/or use this website.
SAP NS2 does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe SAP NS2 collected information about a child, please contact SAP NS2 as described in this Privacy Statement. SAP NS2 will take steps to delete the information as soon as possible. Given that our website and services are not directed to users under 16 years of age, for the avoidance of doubt, SAP NS2 does not sell the Personal Data of any minors under 16 years of age.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We may use cookies, embedded scripts and other similar technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services.
Cookies
Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes:
- to make our Services function properly;
- to improve our Services;
- to make login to our Services easier (such as by remembering your user ID);
- to recognize you when you return to our Services and to remember information you have already provided;
- to track your interaction with the Services;
- to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests;
- and to provide a secure browsing experience during your use of our Services.
We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies.
Your Choices
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
- First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Site may not work properly.
- Third-Party Cookies. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.
- We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences.
Analytics
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic.
Other Tracking Technologies
To see how our Site is performing we sometimes use conversion beacons, tags, scripts and pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We also use these tracking technologies to analyze usage patterns of our Services. The use of these technologies allows us to record that a particular device, browser, or application has visited a particular webpage.
Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
11. DATA SECURITY
We take reasonable measures, including administrative, technical, and physical safeguards, intended to protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information to perform our business purposes, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately as described below.
12. Supplemental notice for california residents.
This section applies solely to individuals who reside in the State of California.
The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of Personal Data, about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act and implementing regulations (together, “CCPA”). Your “right to know” about Personal Data collected, used, and disclosed by SAP NS2 includes what categories of Personal Data we collect from you and the purpose for its collection; how we use those categories of Personal Data; and how we share the Personal Data you entrust to us.
Where SAP NS2 is the CCPA “business” in relation to your Personal Data, You have the right:
- to request from SAP NS2 access to your Personal Data that SAP NS2 collects, uses, or discloses about you;
- to request that SAP NS2 delete Personal Data about you;
- to request that SAP NS2 correct Personal Data about you;
- to opt-out of the use or disclosure of your sensitive personal information;
- to non-discriminatory treatment for the exercise of any of your data protection rights; and
- if you request 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;
- to opt-out of: (i) the sale of your personal information; and (ii) the sharing of your personal information for targeted advertising. While we do not sell your personal information for money, like many websites, we use cookies, pixels, and/or similar technology, and we make available certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under the CCPA’s broad definition of “sell”, this could be considered a sale, and/or it could be considered “sharing” of your personal information for targeted, cross-context behavioral advertising purposes. You have the right to direct us not to sell your personal information to third parties, and to direct us not to share or use your personal information for targeted advertising purposes. To exercise your right to opt-out, please email us as described in the “Contact Us” section below;
- to limit use and disclosure of sensitive Personal Data. If you are a California resident, to the extent your sensitive personal information, as that term is defined under California privacy law, is used to infer characteristics about you, you have the right to object to our processing of your sensitive personal information. We do not use sensitive Personal Data to draw inferences about you;
- not to be subject to a decision which significantly impact your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you;
If you are a California resident, you have the right to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information (Shine the Light, CA S.B. 27, as may be amended from time to time).
Data Subject Access Requests:
SAP NS2 works to ensure all valid data subject access requests for which SAP NS2 is responsible are responded to within the appropriate timeframe. In accordance with the verification process set forth in the CCPA, SAP NS2 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 SAP NS2 must request additional information from you outside of information that is already maintained by SAP NS2, SAP NS2 will only use it to verify your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.
In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:
- Identifiers;
- Personal information categories listed in the CCPA;
- Commercial information; and
- Internet or similar network activity.
Descriptions as to the sources of information, purpose of information and sharing of information are found above in Sections 3, 4 and 6, respectively.
13. CONTACT US
We welcome your questions, comments, and concerns about privacy. You can contact us anytime via our email address at privacy@sapns2.com or our website, at https://www.sapns2.com/contact-us/.
