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Privacy Policy

Last Updated: 25 January 2026

UK GDPR Compliant: This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are committed to protecting your personal data and respecting your privacy rights.

1. Data Controller Information

ProcureFly is the data controller responsible for your personal data.

  • Service Provider: ProcureFly
  • Data Protection Contact: [email protected]
GDPR Commitment: We are committed to complying with UK GDPR and the Data Protection Act 2018 for all our UK users. We apply UK data protection standards to protect your rights and privacy.

2. Information We Collect

2.1 Information You Provide Directly

  • Identity Data: First name, last name, username, title
  • Contact Data: Email address, telephone number, billing address, delivery address
  • Financial Data: Bank account details, payment card details (processed securely via PCI-DSS compliant payment processors)
  • Profile Data: Username, password, preferences, feedback, survey responses
  • Business Data: Company name, job title, RFP documents, vendor information, procurement data

2.2 Information Collected Automatically

  • Technical Data: IP address, browser type and version, time zone setting, browser plug-in types, operating system
  • Usage Data: Information about how you use our website and services
  • Marketing Data: Your preferences in receiving marketing from us and communication preferences

3. Lawful Basis for Processing

Important: Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following legal bases:
Purpose Lawful Basis
To register you as a new customer Performance of a contract
To process and deliver services Performance of a contract
To manage payments and billing Performance of a contract
To manage our relationship with you Performance of a contract / Legal obligation
To send marketing communications Consent (you can withdraw at any time)
To deliver relevant website content and advertisements Legitimate interests
To improve our website, products, and services Legitimate interests
To prevent fraud and ensure security Legal obligation / Legitimate interests

4. How We Use Your Information

We use your personal data for the following purposes:

  • Providing, maintaining, and improving our RFP management platform
  • Processing your transactions and managing your account
  • Sending you service-related communications (not marketing)
  • Responding to your enquiries and support requests
  • Sending marketing communications (where you have consented)
  • Analysing usage to improve our services
  • Detecting and preventing fraud and abuse
  • Complying with legal obligations

5. Data Sharing and Third Parties

5.1 Categories of Recipients

We may share your personal data with:

  • Service Providers: Cloud hosting (AWS/Azure), payment processors (Stripe, PayPal), email providers
  • Professional Advisers: Lawyers, accountants, auditors, insurers
  • Regulators and Authorities: HMRC, ICO, courts (where required by law)
  • Business Partners: Only with your explicit consent

5.2 Requirements for Third Parties

We require all third parties to:

  • Respect the security of your personal data
  • Treat it in accordance with the law
  • Only process your data on our documented instructions
  • Enter into appropriate data processing agreements

6. International Data Transfers

Post-Brexit Transfers: Some of our service providers are based outside the UK. When we transfer your data internationally, we ensure adequate protection through:
  • UK Adequacy Decisions: Transfers to countries deemed adequate by the UK government
  • International Data Transfer Agreement (IDTA): UK-approved standard contractual clauses
  • Binding Corporate Rules: For transfers within corporate groups
  • Additional Safeguards: Encryption, pseudonymisation, access controls

Countries we may transfer data to include: USA, EU Member States, and other jurisdictions with appropriate safeguards in place.

7. Data Retention

We retain your personal data only for as long as necessary. Our retention periods are:

Data Type Retention Period Reason
Account Information Duration of account + 6 years Contractual and legal requirements
Transaction Records 7 years from transaction HMRC requirements
Marketing Preferences Until consent withdrawn Consent-based processing
Support Communications 3 years from resolution Quality assurance
Website Analytics 26 months Statistical analysis

8. Your Rights Under UK GDPR

Your Rights: As a UK data subject, you have the following rights under UK GDPR. These rights are not absolute and may be subject to exemptions.
  • Right of Access: Request a copy of your personal data (Subject Access Request)
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data ("right to be forgotten")
  • Right to Restrict Processing: Request limitation of processing in certain circumstances
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Rights Related to Automated Decision Making: Right not to be subject to decisions based solely on automated processing
  • Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)

How to Exercise Your Rights

To exercise any of these rights, please contact us:

  • Email: [email protected]
  • Subject: "Data Subject Request - [Your Right]"
  • Response Time: We will respond within one month (extendable by two months for complex requests)
  • Fee: No fee for most requests; reasonable fee for excessive or unfounded requests
  • Verification: We may need to verify your identity before processing your request

9. Data Security

We have implemented appropriate technical and organisational measures to protect your personal data:

  • Encryption of data in transit (TLS 1.3) and at rest (AES-256)
  • Multi-factor authentication for account access
  • Regular security assessments and penetration testing
  • Role-based access controls (principle of least privilege)
  • Regular staff training on data protection
  • Incident response and breach notification procedures
  • Regular backups with tested restoration procedures

10. Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms:

  • We will notify affected individuals without undue delay
  • We will take immediate steps to contain and investigate the breach
  • We maintain a breach register recording all incidents
  • For UK users, you may report concerns to the ICO if you believe the breach affects your rights

11. Cookies and Tracking

We use cookies and similar technologies. For full details, please see our Cookie Policy.

12. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected data from someone under 18, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

  • Posting a notice on our website
  • Updating the "Last Updated" date
  • Sending an email notification for material changes

14. Right to Complain

We take data protection seriously and aim to resolve any concerns directly. If you are unhappy with how we have handled your data:

  • Step 1: Contact us first at [email protected] - we will try to resolve your concern within 30 days
  • Step 2: If you are a UK resident and remain unsatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO)
UK ICO Information (for UK residents):
Website: https://ico.org.uk/make-a-complaint/
Helpline: 0303 123 1113

15. Contact Us

For any questions about this Privacy Policy or our data practices:

  • Data Protection Contact: [email protected]
  • General Enquiries: [email protected]
  • Company: ProcureFly

We respond to all data protection enquiries within 30 days.


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