The privacy of your personal data is important to us and we are committed to protecting your privacy. This policy sets out how we collect and use your personal data when you interact with us, including any data that you may provide to us when you:
- visit our website (https://www.mitorxtherapeutics.com) (Website);
- apply for a job with us (whether as an employee, worker or contractor);
- subscribe to receive updates, newsletters or other information from us;
- request information from us or provide information to us; or
- supply goods or services to us (or work for the organisations that do or who we collaborate with).
This policy also applies to Shareholder Data that we might process (as described below).
The Website is not for children and we do not knowingly collect personal data of children.
Contents
- Important Information And Who We Are
- The Types Of Personal Data We Collect About You
- How Is Your Personal Data Collected?
- How We Use Your Personal Data
- Disclosures Of Your Personal Data
- International Transfers
- Data Security
- Data Retention
- Automated Decision Making
- Your Legal Rights
- Contact Details
- Complaints
- Changes To This Policy And Your Duty To Inform Us Of Changes
- Third Party Links
1. Important information and who we are
MitoRx Therapeutics Limited (company number 13237941) (MitoRx, we, our or us) is the controller of, and therefore responsible for, your personal data.
If you have any questions about this policy, including any requests to exercise your legal rights (section 10), please contact us using the information set out in the contact details section (section 11).
2.The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender, as well as organisation details.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Website.
- Usage Data includes information about how you interact with and use the Website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Shareholder and Investor Data includes information relating to our actual, potential or former individual shareholders and investors, as well as representatives of institutional or corporate shareholders and investors of us, which may include details of your participation in our affairs as an individual shareholder or representative of an institutional or corporate shareholder (as applicable) or investor, such as attendance at and contribution to meetings, voting records etc, details of your respective shareholdings and or investments and any other information which is required to be recorded about you as a shareholder and or investor by law or which we hold in relation to your current or former shareholding or investment or which we may acquire in connection with any discussions relating to potential shareholding or investment.
- Candidate Data includes, if you are applying for a role with us, the information you have provided to us in your curriculum vitae and covering letter, the information you have provided on our application form, including education history, qualifications and employment history; any information you provide to us during the course of your application and any interview process (including any assessments undertaken as part of such process), as well as information obtained from sources other than yourself.
We do not collect Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) and Criminal Offence Data (this includes confirming that you do not have a criminal record) about you except in limited circumstances. For example, when you apply for a job with us (if you have any particular access requirements or we need to confirm that you do not have a criminal record before offering you a job with us). Your provision of such data would indicate your consent to us using the data for the relevant purpose. Where we are required to do so by law, we have in place an appropriate policy document and safeguards.
We (and service providers that we use) also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with the Website to help improve the Website. We, or our service providers, may collect and aggregate individuals’ Usage Data in an anonymised form to assess how features that are provided are used and make service improvements and for other business purposes. In some circumstances we also may have access to and use anonymised data from which we cannot identify any individuals.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for a job with us, provide us with feedback or contact us.
Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, web beacons, tags, pixels, server logs and other similar technologies. Please see section 14 below for more information on the cookies we use.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data is collected from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Candidate Data is collected from recruitment agencies, background check providers, Disclosure and Barring service (in respect of criminal convictions), credit reference agencies and your named referees.
- Contact Data is collected from providers of technical services.
- Identity, Candidate and Contact Data is collected from publicly available sources such as Companies House and social media platforms such as LinkedIn.
- How we use your personal data
4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enter into a contract with the organisation that you represent or to prevent fraud and enable us to give you the best and most secure customer experience. Where required, we make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
| Purpose/Use | Purpose/Use | Type of data | Legal basis |
|---|---|---|---|
| General | General | General | General |
To manage our relationship with you which will include:
|
To manage our relationship with you which will include:
|
|
|
| To manage our relationship with you or your organisation as a supplier of goods and services to MitoRx or our collaborator(s) | To manage our relationship with you or your organisation as a supplier of goods and services to MitoRx or our collaborator(s) |
|
|
| To administer and protect our business and the Website (including monitoring of emails received, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | To administer and protect our business and the Website (including monitoring of emails received, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
| To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you | To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
|
| To use data analytics to improve the Website, customer relationships and experiences and to measure the effectiveness of our communications and marketing | To use data analytics to improve the Website, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
|
|
| To send you relevant marketing communications | To send you relevant marketing communications |
|
|
| To enable you to provide us with feedback / to complete a survey | To enable you to provide us with feedback / to complete a survey |
|
|
| To contact you in a case of emergency relating to one of our staff members who has provided your details | To contact you in a case of emergency relating to one of our staff members who has provided your details |
|
|
| Candidates | Candidates | Candidates | Candidates |
| Assess your skills, qualifications and suitability for the role | Assess your skills, qualifications and suitability for the role |
|
|
| Carry out background and reference checks, where applicable | Carry out background and reference checks, where applicable |
|
|
| Communicate with you about the recruitment process | Communicate with you about the recruitment process |
|
|
| Keep records relating to our hiring process | Keep records relating to our hiring process |
|
|
| Comply with legal and regulatory requirements | Comply with legal and regulatory requirements |
|
|
| Equal opportunities monitoring and equalities reporting | Equal opportunities monitoring and equalities reporting |
|
|
| Shareholders and Investors | Shareholders and Investors | Shareholders and Investors | Shareholders and Investors |
| To provide your organisation as a shareholder or investor into MitroRx with information |
|
|
|
| In respect of Shareholder Data, to manage our relationship with our shareholders and to administer our business (including providing newsletter updates to our shareholders) |
|
|
|
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us: info@mitorxtherapeutics.com
5. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below in accordance with this policy.
- The organisation that you represent, who is our customer or supplier.
- Vendors and service providers who support our respective operations such as our CRM system, IT and system administration services, hosting services, email delivery and administration and data storage / analysis.
- Our professional advisors, including our lawyers, auditors and insurers who provide legal, accounting, insurance and other services.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who may wish to invest in our business (or with whom we may discuss any such activity). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
- Shareholders and investors who we provide with information as part of our reporting activities.
- Government and other law enforcement agencies and regulatory bodies (including HMRC) to comply with applicable laws and regulatory requirements.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We may transfer your personal data to service providers that carry out certain functions on our behalf, and this may involve transferring personal data outside the UK.
Some of these countries have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK or EEA to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
- We will only transfer your personal data to countries that have been deemed by the UK or EEA to provide an adequate level of protection for personal data; or
- We may use specific standard contractual terms approved for use in the UK or EEA which give the transferred personal data the same protection as it has in the UK or EEA. To obtain a copy of these contractual safeguards, please contact us (please see section 11).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see section 10 below for further information.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Automated Decision-Making
Automated decision-making means the process of making decisions by automated means with or without any human involvement. We do not make decisions about you based solely on automated processing that would have legal, or similarly significant, effects for you. We will notify you if this position changes.
10. Your legal rights
You have a number of rights under data protection laws in relation to your personal data. These rights apply irrespective of where you are resident.
You have the right to:
- Request access to your personal data (commonly known as a subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see section 4 for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us (please see details (section 11)).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Contact details
If you have any questions about this policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: info@mitorxtherapeutics.com
Postal address: Building 383 Becquerel Avenue, Harwell, Didcot, OX11 0RD
12. Complaints
If you have any questions or concerns about this policy or how we handle your personal data, please contact us using the details provided below.
You have the right to complain to us if you consider that there has been an infringement of your rights in relation to your personal data.
You can submit a complaint using the following channels:
- Email: info@mitorxtherapeutics.com.
- Post: Building 383 Becquerel Avenue, Harwell, Didcot, OX11 0RD.
When we receive a data protection complaint, we will:
- Acknowledge receipt no later than 30 days from receiving it.
- Take appropriate steps to respond without undue delay, which may include making enquiries into the subject matter of the complaint and, where appropriate, keeping you informed about the progress of our handling of the complaint.
- Inform you of the outcome without undue delay.
- You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are based in the EEA, you also have the right to complain to your national data protection regulator.
- However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.
13. Changes to this policy and your duty to inform us of changes
We keep this policy under regular review. This version was last updated: May 2026.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
14. Third-party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.