BetaGlue Therapeutics S.p.A. (hereinafter also “BetaGlue”), in its capacity as Data Controller of Personal Data (hereinafter, “Data Controller”), pursuant to EU Regulation 2016/679 (hereinafter: “Regulation”) – considers the protection of Personal Data to be one of the company’s main objectives.
We therefore invite you, before transmitting any personal data to the Data Controller, to read this Privacy Policy carefully.
“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors referred to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
This document refers to the data processing carried out in the performance of the company’s institutional activity and through the interaction with the website. For information regarding personal data processing within clinical trials or other specific relationships, please refer to the specific information notices provided at the time of data collection.
This document has, therefore, the function of disclosing the company’s privacy policy, and allows to understand how the personal information of the data subjects is processed by the company, in compliance with GDPR 2016/679.
According to the provisions of the Regulation, the processing carried out by the company is based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality.
The Data Controller
The Data Controller of personal data is BETAGLUE THERAPEUTICS S.P.A., in the person of the legal representative in force, with registered office in Via della Moscova n.3, 20121 Milan, Italy.
The Data Controller can be contacted at the following email address: privacy@betaglue.com
The Data Controller has appointed a Data Protection Officer (DPO), who can be contacted for any clarification or exercise of rights at the following email address: dpo@betaglue.com
Personal Data subject to processing
The company processes:
- personal identification and contact data (such as name, surname, email) provided voluntarily by the user through contact forms or newsletter subscription
- browsing data and technical cookies necessary for the operation of the website
Purposes of processing
The processing of data carried out by BetaGlue has the purposes to allow, in relation to the company website:
- User access to the pages, contents and services of the Website and to its functionality
- Feedback to requests of contact or information sent by the User
- Subscription to the e-mail newsletter to receive updates on our programs and latest discoveries
- Statistical analysis of website usage through dedicated cookies
Basis of legitimacy and mandatory or optional nature of the processing
The legal basis for the processing of Personal Data is:
- For User access to the Website and technical cookies: Art. 6 (1) (f), for the exercise of the legitimate interest aimed at granting a coherent user experience and functionality of the site
- For feedback to contact requests: Art. 6 (1) (f), for the exercise of the legitimate interest aimed at maintaining relations with Users of the Website
- For the subscription to the newsletter: Art. 6 (1) (a), on the basis of the explicit consent given by the Data Subject
- For statistical analysis cookies: Art. 6 (1) (a), on the basis of the consent given by the Data Subject
Recipients of Personal Data
Personal Data may be shared, for the purposes referred to in the dedicated section, with:
- Subjects who typically act as data processors pursuant to Article 28 of the Regulation, namely: i) persons, companies or professional firms that provide assistance and advice to BetaGlue; ii) subjects with whom it is necessary to interact in order to carry out BetaGlue’s institutional activities; iii) subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communications networks); (collectively “Recipients”). The list of data processors can be requested to the Data Controller
- Subjects, bodies or authorities, autonomous data controllers, to whom it is mandatory to communicate Personal Data in compliance with legal provisions or orders of the authorities
- Persons specifically authorised by BetaGlue (e.g. employees and contractors)
Data Retention
Personal Data processed for the purposes referred to above will be kept for the time strictly necessary to achieve those same purposes. In particular:
- Contact data for requests will be kept for the time necessary to fulfill the request and for a further period of 12 months following the last interaction, to ensure consistency in feedback, unless legal obligations require a longer retention
- Newsletter data will be processed until the consent is withdrawn (unsubscribe)
- Analytics data will be processed according to the time frame specified in the cookie policy. It is also noted that the User can delete the analytics cookies at any time from their device
International Data Transfer
Data transfers to and from countries outside the European Economic Area (EEA) are carried out in compliance with the conditions of legitimacy set out in the Regulation.
Specifically, when using third-party services integrated into the Website (such as video hosting services), personal data may be transferred to the United States. In such cases, BetaGlue ensures that the transfer is based on adequacy decisions by the European Commission (such as the EU-U.S. Data Privacy Framework) or through the adoption of Standard Contractual Clauses, in order to guarantee a level of protection for natural persons equivalent to that guaranteed within the EEA.
Further information regarding the specific safeguards adopted for each service can be requested by writing to the email addresses indicated above.
Rights of the data subjects
The company guarantees the exercise of the rights of the data subjects, where applicable and in relation to non-anonymous data, pursuant to articles 15 et seq. of the Regulation, such as:
- right of access to Personal Data;
- their rectification or cancellation;
- restriction of processing in the cases provided for by art. 18 of the Regulation;
- right to obtain personal data in a structured, commonly used and machine-readable format, in the cases provided for by art. 20 of the Regulation;
- right to object and revoke consent
- right to file a complaint with the competent supervisory authority pursuant to Article 77 of the Regulation (Guarantor for the Protection of Personal Data WWW.GARANTEPRIVACY.IT).
This section informs Users about the processing of their personal data resulting from their interaction with the Official Page of BetaGlue Therapeutics S.p.A. on the LinkedIn platform.
Data Controllership Roles
The processing of personal data on BetaGlue’s LinkedIn Official Page involves different levels of responsibility:
- BetaGlue as Independent Controller – BetaGlue acts as an autonomous Data Controller for the management of its Official Page and the interactions occurring therein (such as responding to comments or private messages).
- LinkedIn as Independent Controller – LinkedIn (LinkedIn Ireland Unlimited Company) acts as an autonomous Data Controller for all processing related to the platform’s general operation, such as profiling, tracking, and advertising for its own purposes. For these activities, please refer to LinkedIn’s Privacy (https://www.linkedin.com/legal/privacy-policy).
- Joint Controllership (Page Insights) – BetaGlue and LinkedIn Ireland act as Joint Controllers pursuant to Art. 26 GDPR solely for the processing of data used to generate “Page Insights” (aggregated statistics on page performance). In this context, LinkedIn is primarily responsible for providing information about such processing and enabling the exercise of data subject rights. You can review the Joint Controller Addendum at https://www.linkedin.com/legal/l/page-joint-controller-addendum.
Categories of Data and Purposes
When you interact with our Official Page, we may process:
- Identification and contact data (name and professional information shared through your profile)
- Interactions (public activities such as “likes”, comments, or shares)
- Private messages (information provided through direct messages sent to our page)
- Statistics (aggregate data regarding page engagement provided by LinkedIn – Insight).
These data are processed based on our legitimate interest (Art. 6.1.f GDPR) to maintain and manage relationships with our professional community and stakeholders.
Data Retention
Personal data collected through interaction with the Official Page are retained for the duration of the interaction between the User and the page, or until the specific processing activity related to the page is concluded.
Rights and Contacts
To exercise your rights under the GDPR, please refer to the following contact points depending on the nature of the processing:
- LinkedIn Platform Activities – For processing activities where LinkedIn acts as an independent controller (e.g., profile settings, platform-wide tracking), please contact LinkedIn directly through its privacy channels.
- Page Insights (Joint Controllership) – In accordance with the LinkedIn Joint Controller Addendum, LinkedIn Ireland has been designated as the primary contact point for exercising your rights regarding Page Insights data. We recommend addressing your requests to LinkedIn Ireland preferentially.
- BetaGlue Interactions – For activities where BetaGlue acts as an independent controller (e.g., management of comments or private messages), you may contact our Privacy Manager at privacy@betaglue.com or our DPO, Alessandro Rossini, at dpo@betaglue.com.
Changes
BetaGlue reserves the right to modify or simply update the content of this policy, in part or in full, also due to changes in the applicable legislation.