Last updated: June 2025
Note: This document is a general template provided for the website of PCL Research&Manufacturing s.r.l. It should be reviewed and finalised by a qualified data-protection / legal professional before publication, to ensure full compliance with Regulation (EU) 2016/679 (GDPR), Italian Legislative Decree 196/2003 (as amended) and any sector-specific obligations.
PCL Research&Manufacturing s.r.l. ("PCL Research & Manufacturing", "we", "us") respects your privacy and is committed to protecting the personal data we process. This Privacy Policy explains what data we collect through this website, how we use it, and the rights you have under the General Data Protection Regulation (EU) 2016/679 ("GDPR").
1. Data Controller
The data controller is PCL Research&Manufacturing s.r.l., with registered office at Via F.S. Fabri, 127/1, 40059 Medicina (BO), Italy — VAT IT02775010743.
2. What data we collect
Depending on how you interact with us, we may process the following categories of personal data:
- Contact data you voluntarily provide through our contact or careers forms (e.g. first name, last name, company, email address, telephone number).
- Application data contained in your CV and cover message when you apply for a position (e.g. professional experience, education, qualifications).
- Communication content — the information contained in the messages you send us.
- Technical and usage data automatically collected through cookies and similar technologies (e.g. IP address, browser type, pages visited). See our Cookie Policy.
3. Purposes and legal basis of processing
| Purpose | Legal basis (GDPR Art. 6) |
|---|
| Responding to enquiries and providing quotes | Steps taken at your request prior to entering a contract (Art. 6(1)(b)) |
| Managing job applications | Steps prior to a possible employment relationship / your consent (Art. 6(1)(b)/(a)) |
| Providing and securing the website | Legitimate interest (Art. 6(1)(f)) |
| Analytics and non-essential cookies | Your consent (Art. 6(1)(a)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
4. How long we keep your data
We retain personal data only for as long as necessary for the purposes described above. Enquiry data is generally kept for the duration of our communications and a reasonable period thereafter; application data is retained for the time needed to evaluate your candidacy and, where applicable, for future opportunities (with your consent). Data may be kept longer where required to comply with legal obligations or to defend legal claims.
5. Who we share data with
Your data may be shared with trusted third parties acting as data processors on our behalf (e.g. IT and hosting providers), bound by appropriate data-processing agreements. We do not sell your personal data. Where data is transferred outside the European Economic Area, we ensure appropriate safeguards in accordance with the GDPR.
6. Your rights
Under the GDPR you have the right to:
- Access your personal data and obtain a copy of it
- Request rectification of inaccurate or incomplete data
- Request erasure ("right to be forgotten") where applicable
- Request restriction of processing
- Object to processing based on legitimate interest
- Data portability
- Withdraw consent at any time, without affecting prior lawful processing
- Lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali)
To exercise your rights, contact us at info@pcl-rm.com.
7. Data security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure.
8. Artificial intelligence and the EU AI Act
PCL Research & Manufacturing is developing CrystallQ, an AI-supported platform that ranks probable crystal forms, packing motifs and salt or co-crystal candidates for pharmaceutical compounds. We develop and intend to operate it in line with Regulation (EU) 2024/1689 (the AI Act) and with the GDPR. The following principles govern its development and use:
- Scientific decision support, not automated decision-making. CrystallQ produces predictions and rankings that inform experimental design. Every output is reviewed and interpreted by qualified PCL Research & Manufacturing scientists, and no result is issued to a client without human assessment. The platform makes no decisions about individuals and performs no profiling.
- Training data. The models are trained on PCL Research & Manufacturing's own crystallization and analytical datasets and on scientific and structural data relating to chemical compounds. They are not trained on personal data, and client data is never used to train models serving other clients.
- Transparency. Where a deliverable includes AI-generated predictions, this is stated explicitly, together with the nature of the output and its limitations. Predictions are probabilistic and do not replace experimental verification.
- Human oversight and accountability. Defined roles, review steps and record-keeping accompany the use of the platform, so that outputs remain traceable and challengeable.
- Confidentiality. Compounds, structures and results submitted by clients remain confidential under the applicable agreements and are segregated from other projects.
- Data governance and robustness. Datasets are curated and documented, and model performance is validated against PCL Research & Manufacturing's own experimental results before predictions are used in client work.
- Risk classification. CrystallQ is intended for use in industrial research and development on chemical substances. It is not designed or offered for any of the purposes that the AI Act classifies as prohibited or high-risk, and in particular it is not a medical device, does not assess persons and does not support decisions about individuals. Should the intended purpose change, we will reassess its classification and the resulting obligations before deployment.
For questions about our use of AI, or to request further information on how a specific prediction was produced, contact us at businessdev@pcl-rm.com.
9. Changes to this policy
We may update this Privacy Policy from time to time. The "last updated" date above indicates the latest revision.