Privacy Notice

A. Scope of this Privacy Notice

This notice provides you with information about the processing of personal data by Keelvar Systems Limited when handling Personal Data in the context of your service contract with us as defined in the Keelvar SaaS Terms & Conditions  (hereinafter collectively referred to as (our) “Service”).

Personal Data in the context of our service (referred to as “Service Personal Data”) is personal data that is provided by You, which resides in the Keelvar SaaS or third-party systems, and is processed by Keelvar on Your behalf in order to perform a Service. Services Personal Data may include: your name, contact details, IP address, payment details, online identifiers such as IP addresses or user UUID. Services Personal Data may also relate to your representatives and end users, such as your employees, contractors, collaborators, partners and suppliers.Keelvar SaaS differentiates between two groups of users: purchasers and bidders. The two groups differ in available functionality. This Privacy Notice will highlight any substantial difference in the processing of personal data between the two user groups.

B. About Us

KEELVAR SYSTEMS LIMITED, Suite 2B, 6 Lapps Quay, Cork, T12 PPX3, Ireland. Keelvar Systems Limited (also referred to as Keelvar) acts as a processor on behalf of our customers in relation to your responsible use of the functionalities of our Service as described in the Terms & Conditions.To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

C. Categories of Data

I. User account information

When your admin user connects and uses Keelvar SaaS for the first time, we collect information from you to set up the first users. This may include the name, contact details such as email/phone number, online identifiers such as IP address. From this information, we create a unique user identifier (UUID), that enables Keelvar SaaS to identify users in the system. Your admin user is able to invite additional users to take advantage of the service. When inviting users, we process the same personal data for each additional user.

II. Session Connection

Every time you connect to Keelvar SaaS, the Keelvar server infrastructure will register you, collecting and processing your login credential, IP address and UUID. In addition, we also collect certain Session Metadata such as a Session ID, session logs and usage data.

III. Service Support Requests

When you contact our support, we will collect your name, time and date of your request, your email-address, your telephone number should you provide it as well as the content of your request.

IV. User generated content

Users are able to upload files and exchange direct messages between users from purchaser and supplier organizations. We process your name, email, the message content and any files and information you may upload to the Keelvar SaaS.

V. Purchasers / Bidders selection

Purchaser users are able to identify specific bidders by matching against the selection criteria defined by the purchaser user. To identify the intended bidder, we process your name, email address and user UUID.

VI. Training (optional service)

When providing user training we process your email address, name, training logs, user profile picture (if set) and user department/company.

VII. Service Subscription Payment (optional service)

If you have a subscription with Keelvar, we may process your name and credit card details. We may process your payment details for the purpose of setting up and renewing a service subscription.

VIII. Cookies

When you visit the Keelvar SaaS website, cookies are stored on your computer. Cookies are small text files that are stored on your hard disk and serve to make our service more user-friendly and effective. This website only uses “strictly necessary” cookies which do not require your consent. This website uses the following “strictly necessary” cookies which do not require your consent.




Security cookie providing protection against Cross Site Request Forgeries attacks.


Maintains the id for an authentication session ensuring you remain logged in while you use Keelvar SaaS.


Expiry timestamp of authentication token.


Organisation unique identifier.


User unique identifier.


The user locale to assist with localization e.g. date and time formatting.


Track user opt-in or opt-out of Analytics tracking.Expiration: 12 months

The website also uses the following analytics cookies which require your consent.




Used to store details about a user, such as a unique ID, to distinguish between a new or returning visitor. Expiration: 13 months


Session cookie used to store information related to a recent visit for anonymous statistics. Expiration: 30 minutes


Used for heatmap analytics (mouse movements, clicks, etc.) to make improvements to the user experience. Expiration: 30 minutes

D. Purpose and legal basis for processing

I. Processing for the purpose of providing you with a service [Keelvar acting as a Data Processor]

Keelvar Systems Limited will process personal data as the Customer's Processor in order to enable the use of Keelvar SaaS Services as defined under the Terms & Conditions, the customers documented instructions and ordered service functionality. This covers the processing of the transmitted content as well as the organization of the contents of the user accounts. When using Keelvar SaaS, Keelvar Systems Limited will carry out the following processing of personal data on behalf of the customer:

  • Processing of data in the context of user registration and session management.
  • Processing user generated content such as messages between bidders and purchasers as well as file uploads.
  • Processing user details when selecting or filtering bidders to match purchaser search preferences.
  • Processing in the context of supporting the customer to resolve service issues.
  • Processing customer details to provide product training (optional service).
  • Processing customer details to provide acquired services (optional service such as managed events, event success center)
  • Processing payment details for the purpose of setting up or renewing your service subscription (optional service).
  • Processing Bidder contact details for the purpose of recommending the Bidder to Purchasers where the Bidder has previously participated in events of a similar nature.

Our legal basis to process your personal data is performance of our contract with you.

II. Processing for the purpose of enhancing the service we provide to you [Keelvar acting as a Data Controller]

Our legal basis to process your personal data is performance of our contract We strive to continuously improve the experience of using our Service. In order to do so, we need to better understand and categorize the needs of our customers. To achieve this, we may analyze how you use our Service as described above. This way, we gather information that is required to improve and further develop our Service, e.g. to help us decide whether we should keep or amend functionalities the Service currently has or whether to create new features, functionalities or documentation. Our legal basis for processing such information is our legitimate interest in performing, maintaining and securing our products and services and operating our business in an efficient and appropriate manner.with you.

III. Processing for the purpose of general systems operations [Keelvar acting as a Data Controller]

We may process personal data as part of the normal operation of Keelvar SaaS for the following purposes:

  • to help keep our services secure including for security monitoring and identity management;
  • to administer our back-up disaster recovery plans and policies;
  • to confirm compliance with our terms of use (license compliance monitoring);

Our legal basis for processing such information is our legitimate interest in performing, maintaining and securing our service and operating our business in an efficient and appropriate manner.

IV. Processing to fulfill legal obligations [Keelvar acting as a Data Controller]

Personal information may also be processed based on our legal obligations or legitimate interest to comply with such legal obligations.

V. Automated decision making [Keelvar acting as a Data Controller]

Keelvar SaaS uses automatic decision-making to recommend bidder contacts to Purchasing organizations in the context of a Sourcing event where a Bidder has previously participated in a similar event. A Bidder can opt out of this processing. Our legal basis for processing such information is performance of our contract with you.

E. Statutory/contractual requirement

You may choose not to provide personal data or provide incomplete personal data. However, you should be aware that, as a result, we may not be able to provide your service or engage in a contractual relationship with you or provide you with adequate support.

F. Sharing personal information

Keelvar engages third party sub-processors to have access to Services Personal Data in order to assist in the provision of our Service, such sub-processors shall be subject to the same level of data protection and security as Keelvar under the terms of your service. Keelvar maintains lists of sub-processors that may process personal data as documented in our data processing agreement.

G. International Transfers

Keelvar is based in Ireland and the personal data held in Keelvar SaaS is processed in data centers located in the EEA. If your Personal Data is transferred to a recipient in a country that does not provide an adequate level of protection for personal information, we will take adequate measures designed to protect the Personal Data, such as ensuring that such transfers are subject to the terms of the EU Model Clauses or other adequate transfer mechanism as required under relevant data protection law.

H. Retention periods for personal data

Except as otherwise specified in your service upon termination of services or at your request, Keelvar will delete your customer data including its back-ups held in our data stores within 60 days or by our sub-processors unless there is a legal obligation imposed on Keelvar preventing it from deleting all or part of the data.

I. Data Subject Rights

Our customers control access to the Personal Data for their end users, and the end user should direct any requests related to their Personal Data directly to the organization they work for. To the extent such access is not available to You, Keelvar will provide reasonable assistance with facilitating such requests from individuals. This may include your right to access, delete or erase, restrict, rectify, receive and transmit, block access to or object to processing of Personal Data in Keelvar SaaS.

J. Right to Lodge a Complaint

If you have any cause to complain about our use of your personal data, you have the right to lodge a complaint with the Data Protection Commission in Ireland. Should you have any questions on the processing of personal data through Keelvar SaaS, please contact

K. Changes to this Services Privacy Notice

The Privacy Notice can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In cases of material changes, we will also inform you in another appropriate way prior to the changes becoming effective.

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