How we handle your personal data and protect your privacy rights.
About This Policy
This Privacy Policy applies to www.polirna.bio, PoliRNA’s corporate website (the “Website”). It explains how we handle personal data when you visit the Website or submit a partnership enquiry through our contact form. It also explains how you can exercise your data protection rights.
It does not cover research or clinical activities outside the Website.
At a glance: POLIRNA S.R.L. is the data controller. We process information submitted through the partnership form to assess and respond to enquiries and manage related correspondence. The sections below explain the processing associated with the Website, the service providers involved and your data protection rights.
Who Is Responsible for Your Data?
The data controller is POLIRNA S.R.L. (“PoliRNA”, “we” or “us”).
Registered office: Via Vincenzo Vela 42, 10128 Torino (TO), Italy
VAT number / Tax code: 13019190019
Privacy contact: info@polirna.bio
Partnership Enquiries
Information you provide
Our partnership form asks for your name, email address, organisation, role or title, and a message describing your interest in a partnership.
The form marks your name, email address and message as required. It does not mark organisation and role or title as required.
We also process any personal data you choose to include in your message. Please provide only information relevant to your enquiry and avoid including health information, genetic data or other sensitive personal information.
Why we use it
We use the information to receive, assess and respond to your partnership enquiry and to communicate with you about it.
Legal basis: Our legitimate interest in assessing potential business partnerships and responding to enquiries addressed to us, under Article 6(1)(f) GDPR. We use the information for the enquiry and related correspondence, rather than unrelated marketing.
Submitting an enquiry is voluntary. Required fields are identified in the form.
How your enquiry is handled
Partnership enquiries submitted through the Website form are sent to PoliRNA’s designated email inbox. PoliRNA’s founders responsible for partnership discussions use the information you submit to assess your enquiry, respond to you and, where appropriate, contact you again about the same enquiry or any resulting partnership discussions.
We process your contact details, the content of your enquiry and any subsequent correspondence for these purposes. Information about the Website and email service providers is set out in the “Who Receives Your Data?” section.
Retention: We retain your enquiry and related correspondence while we assess your request and conduct any resulting partnership discussions. If no partnership proceeds, we delete the correspondence once those discussions are closed and no response or agreed follow-up remains outstanding. If a partnership proceeds, we retain correspondence needed to establish or manage that relationship under the applicable partnership-record retention arrangements. Any information retained to meet a specific legal obligation or address a concrete legal claim is limited to what is needed for that purpose.
Website Data and Analytics
The Website is hosted on Framer. Technical data, such as IP addresses and browser information, may be processed to deliver the Website and maintain its security.
Framer provides built-in website analytics which, according to its documentation, do not use cookies or persistent identifiers and provide anonymous statistics about website use. Further information is available in Framer’s GDPR and cookies documentation.
Who Receives Your Data?
Website hosting and forms: Framer
We use Framer B.V., based in Amsterdam, the Netherlands, to host the Website and provide its contact form. Framer processes personal data on our behalf when providing the services covered by its Data Processing Addendum.
This includes the name, email address, organisation, role or title and message you submit through the form. Technical data associated with Website delivery and analytics is described in the “Website Data and Analytics” section. Details of the processing framework are set out in Framer’s Data Processing Addendum.
Email: Namecheap Private Email
We use Namecheap Private Email to receive and store partnership enquiries and related correspondence. This involves processing the information contained in those messages and the associated email delivery data, such as sender and recipient addresses, subject lines and delivery timestamps.
For further details about email delivery logs and spam filtering, see Namecheap’s email-service documentation.
Namecheap’s Data Processing Addendum identifies Namecheap, Inc. and its affiliates as processors of customer personal data when providing the covered services. Further information is available in Namecheap’s Data Processing Addendum and Private Email Terms of Service.
International Transfers
We use Framer for Website hosting and contact-form services, and Namecheap Private Email for partnership enquiries and related correspondence. These services involve processing outside the European Economic Area (EEA), including in the United States.
Framer
Framer’s published security documentation states that its services are hosted in Amazon Web Services facilities in the United States. Its Data Processing Addendum sets out the framework for international transfers, including adequacy decisions where applicable and Standard Contractual Clauses or other appropriate safeguards where required.
Namecheap Private Email
Namecheap’s published datacenter information lists its Private Email servers in the United States. Its Data Processing Addendum addresses transfers outside the EEA and provides for Standard Contractual Clauses under the conditions specified in that document.
Further information about the providers’ transfer arrangements is available through the links above. To request information about the safeguards applicable to your personal data, including how to obtain a copy, contact info@polirna.bio.
Your Rights
Subject to the conditions and exceptions in the GDPR, you may:
Access your personal data and obtain a copy and information about its processing.
Correct inaccurate data or complete incomplete data.
Request deletion of your data where the legal conditions are met.
Restrict processing in the circumstances provided by law.
Data portability: Where processing is carried out by automated means and is based on your consent or a contract with you, receive the personal data you have provided in a structured, commonly used and machine-readable format and transmit it to another controller. You may also request direct transmission where technically feasible, without adversely affecting the rights and freedoms of others.
Withdraw consent at any time where processing relies on it, without affecting the lawfulness of processing before withdrawal.
Where processing is based on legitimate interests, you may object at any time on grounds relating to your particular situation. We must stop that processing unless we demonstrate compelling legitimate grounds overriding your interests, rights and freedoms, or processing is needed for legal claims.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, subject to the exceptions and safeguards provided by the GDPR.
Review of enquiries: Enquiries submitted through the Website are currently read and assessed only by PoliRNA’s founders, who determine whether and how to respond.
How to make a request
Email info@polirna.bio, explaining your request and the Website interaction concerned.
If we have reasonable doubts about your identity, we may ask for additional information necessary to confirm it.
We will respond without undue delay and, in any event, within one month of receiving your request. Where necessary, taking into account the complexity and number of requests, we may extend this period by two further months. We will notify you of any extension and the reasons for it within one month of receiving your request.
Requests are free of charge. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee reflecting the administrative costs or refuse to act on it, as permitted by the GDPR. We bear the burden of demonstrating that the request is manifestly unfounded or excessive. If we do not act on your request, we will inform you without delay and, at the latest, within one month of receiving it, explaining the reasons and your options for lodging a complaint and seeking a judicial remedy.
Complaints
If you believe your personal data is being processed unlawfully, you may lodge a complaint with a competent supervisory authority, particularly in the EU Member State where you usually live, work or where the alleged infringement occurred.
In Italy, this is the Garante per la protezione dei dati personali:
You do not need to contact PoliRNA before lodging a complaint. You may also seek a judicial remedy.
Data Security
Framer’s published security documentation describes encryption in transit and at rest and access restrictions based on need to know for its services. These safeguards are stated by Framer and do not describe every system used by PoliRNA.
Changes to This Policy
We may update this policy when Website processing activities, services, technologies or applicable legal requirements change. The date at the top shows when the policy was last updated.
If we intend to process your data for a new purpose, we will provide the relevant information before we begin that further processing. Updating this policy does not itself constitute your consent.
Last updated: September 2026