This privacy policy applies to the website procurement.academy and to visitors and users who are citizens and legal permanent residents of the European Economic Area and Switzerland. It explains what personal data we collect, why, and what rights you have. Last updated: July 2026.

1. Who we are

procurement.academy is operated by Masulli Management Ltd, a company registered in Cyprus (company number HE 449361, VAT CY60038600T), with registered office at 5 Artemidos Avenue, Artemidos Tower, 8th Floor, 6020 Larnaca, Cyprus (“we”, “us”, “our”). We are the data controller for the personal data described in this policy. For any privacy question or request, contact us at info@procurement.academy.

2. What personal data we collect, why, and for how long

We only collect the data we need to run the website and deliver our courses.

• When you contact us (contact form or email): your name, email address and message. We use this to answer your enquiry. Legal basis: our legitimate interest in responding to you, or steps taken at your request before entering a contract. We keep it for as long as needed to handle the request and a reasonable period afterwards.
• When you create an account: your name, email address and password. We use this to create and manage your account and to give you access to the courses you buy. Legal basis: performance of a contract. We keep it until you delete your account or ask us to.
• When you buy a course: your name, email, billing address and, for businesses, company name and VAT number. Payments are processed by our payment providers (Stripe and PayPal); we do not receive or store your full card details. We use this data to process your purchase, give you access, issue an invoice and meet our tax and accounting obligations. Legal basis: performance of a contract and compliance with a legal obligation. Invoice and transaction data are kept for the period required by applicable tax law.
• When you subscribe to our newsletter: your email address. We use it to send you updates about new courses and content. Legal basis: your consent. We keep it until you unsubscribe.
• While you take a course: your progress, quiz results and the certificates you earn. We use this to deliver the learning experience and issue your certificate. Legal basis: performance of a contract.
• Automatically: your IP address, browser and device information, and usage data collected through server logs and security tools. We use this to keep the site secure, prevent abuse and operate the service. Legal basis: our legitimate interest in security and in running the website.

3. Cookies

The website uses cookies and similar technologies that are necessary to operate it, for example to keep you logged in, remember your cart, and protect forms from automated abuse. With your consent, we may also use cookies for analytics or marketing. You can manage or withdraw your preferences through your browser settings and, where shown, the cookie banner.

4. Who we share your data with

We do not sell your personal data. We share it only with the service providers (“processors”) we need to run the website, each under an appropriate data-processing agreement:

• Hosting: our website and data are hosted on servers located in the European Union (OVH).
• Payments: Stripe and PayPal process your payments securely.
• Email: Zoho provides our mailboxes and sends our transactional messages, such as order confirmations and password resets.
• Newsletter: if you subscribe, Mailchimp manages our mailing list.
• Security: Cloudflare provides bot protection (Turnstile) on our forms.

We may also disclose personal data where required by law or a court order, to protect our rights, or in the context of a business transfer such as a merger or acquisition.

5. International transfers

Our website and primary data are hosted in the European Union. Some of our providers (for example payment or newsletter services) may process data outside the EEA. Where they do, the transfer is protected by appropriate safeguards, such as the EU Standard Contractual Clauses or an adequacy decision.

6. Security

We take appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access, including encryption in transit (HTTPS) and access controls. We review these measures regularly.

7. Your rights

If you are in the EEA or Switzerland, you have the right to access your personal data, to have it corrected or deleted, to restrict or object to its processing, to data portability, and to withdraw your consent at any time. To exercise any of these rights, contact us at info@procurement.academy. We will respond within the period required by law.

8. Third-party websites

Our website may contain links to other websites, for example LinkedIn or our payment providers. This privacy policy does not apply to those sites, and we are not responsible for their content or practices. Please read their own privacy policies.

9. Changes to this policy

We may update this policy from time to time. The current version is always available on this page, together with the date it was last updated.

10. Complaints

If you believe we have not handled your personal data properly, please contact us first at info@procurement.academy. You also have the right to lodge a complaint with a supervisory authority: for us this is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (dataprotection.gov.cy), or the data protection authority in your own country of residence.

11. Contact

Masulli Management Ltd
5 Artemidos Avenue, Artemidos Tower, 8th Floor, 6020 Larnaca, Cyprus
Email: info@procurement.academy