> SAP Commerce Cloud under the GDPR: storefront cookies, EU hosting, legal bases for orders and marketing, third party transfers and consent guidance.
>
> Canonical: https://www.flowconsent.com/en/services/ecommerce/sap-commerce-cloud

E-commerce

# SAP Commerce Cloud

Preferences · [Official website](https://www.sap.com/products/commerce-cloud.html)

SAP Commerce Cloud is an enterprise B2B and B2C commerce platform from SAP that hosts product catalogues, checkout and order management in the cloud, with EU hosting available on Microsoft Azure.

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At a glance

- Category

  [E-commerce](https://www.flowconsent.com/en/services/ecommerce)

- Consent

  Preferences

- Prior consent

  Required

- Documented cookies

  3

- Third-party domains

  3

- Servers

  European Union (Microsoft Azure West Europe), with optional regional hosting

Overview

## What does SAP Commerce Cloud do?

## What SAP Commerce Cloud is

SAP Commerce Cloud is the enterprise B2B and B2C commerce platform of SAP SE, the German software vendor headquartered in Walldorf. It runs on Microsoft Azure with EU regions available for European customers. Large retailers, manufacturers and wholesalers use it for catalogues, checkout, order management, B2B contracts and omnichannel experiences.

## Data and cookies set

On the storefront, SAP Commerce Cloud sets JSESSIONID for the shopping session, an anonymous cart identifier and CSRF tokens. These are strictly necessary. Marketing, recommendation and personalisation modules add additional cookies that require consent.

## GDPR and ePrivacy implications

The session and order data are processed under Article 6(1)(b) GDPR (performance of a contract). Marketing personalisation, behavioural recommendations and email tracking pixels require consent under Article 6(1)(a) GDPR and Article 5(3) ePrivacy.

## Consent requirements

You do not need consent for the strictly necessary cookies, but the marketing and personalisation features must be gated behind a consent management platform that records valid consent before activation. The newsletter, push notifications and product recommendation cookies must default to off.

## Data transfers outside the EEA

With Azure EU regions, customer data stays within the European Union by default. Sub processors should be reviewed: SAP support, Azure global support and any extension marketplace partner can introduce US access that needs SCCs and a transfer impact assessment.

## Practical compliance steps

Pin the deployment to an Azure EU region, enable role based access control, integrate a CMP that blocks marketing scripts before consent, run a DPIA for personalisation modules, document SAP and Azure sub processors, and align checkout messages with the right consent or contract basis.

Compliance

## SAP Commerce Cloud and the GDPR

SAP Commerce Cloud is classified as “Preferences”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

- Legal basis

  Performance of a contract (Article 6(1)(b) GDPR) for order processing, plus consent (Article 6(1)(a) GDPR and Article 5(3) ePrivacy) for marketing cookies and personalisation

- Risk level

  medium

- Applicable regulations

  GDPR, ePrivacy Directive 2002/58/EC, French CNIL guidelines, German TDDDG, Spanish LSSI, PCI DSS

### Impact assessment (DPIA)

A DPIA is recommended for the marketing personalisation and recommendation modules and for any integration that processes special categories of data or large volumes of payment information. EU hosting on Azure simplifies the third country analysis.

### Sample text for your banner

> Our online store is powered by SAP Commerce Cloud, operated by SAP SE (Germany). Personal data needed to process your order is hosted on EU infrastructure on Microsoft Azure. Marketing and personalisation cookies are activated only with your prior consent.

Cookies and trackers

## What SAP Commerce Cloud sets and contacts

- Tracking method

  server\_side

- Server location

  European Union (Microsoft Azure West Europe), with optional regional hosting

### Cookies set (3)

| Name           | Type         | Duration | Purpose                                                                                            |
| -------------- | ------------ | -------- | -------------------------------------------------------------------------------------------------- |
| JSESSIONID     | first\_party | Session  | Maintains the visitor session with the SAP Commerce Cloud application server (strictly necessary). |
| anonymous-cart | first\_party | 30 days  | Stores the anonymous cart identifier so the visitor can resume shopping (strictly necessary).      |
| XSRF-TOKEN     | first\_party | Session  | CSRF protection token for secure checkout requests.                                                |

### Third-party domains contacted (3)

- `cx.eu.commerce.ondemand.com`
- `api.eu.commerce.ondemand.com`
- `launchpad.support.sap.com`

Questions

## Frequently asked questions about SAP Commerce Cloud

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### Which cookies does SAP Commerce Cloud set?

Strictly necessary cookies for the session (JSESSIONID), the anonymous cart and CSRF tokens. Marketing, recommendation and personalisation modules add consent based cookies.

### Do I need consent to use SAP Commerce Cloud?

Not for the core checkout cookies, which are necessary to perform the contract. Yes for the marketing, recommendation and personalisation modules.

### What is the legal basis?

Article 6(1)(b) GDPR for order processing, Article 6(1)(a) GDPR and Article 5(3) ePrivacy for marketing cookies and personalisation.

### Are any data transferred to the United States?

In standard EU configuration, no. Customer data stays in the chosen Azure EU region. Watch for sub processors (SAP support, Azure global support, marketplace extensions) that may introduce US access.

### Is a DPIA needed?

Recommended for personalisation, recommendation and any module processing special categories of data or large volumes of payment information.

### How do I implement compliance correctly?

Pin to an Azure EU region, integrate a CMP, gate marketing and personalisation behind consent, run a DPIA for new modules, document SAP and Azure sub processors.

### What are the alternatives?

Adobe Commerce (Magento), Salesforce Commerce Cloud, commercetools, Spryker, Shopify Plus and BigCommerce. EU based options simplify the third country analysis.

### How do I update the cookie policy?

Run a scanner monthly across staging and production, document strictly necessary versus consent based cookies separately, and version the policy in your CMS.

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