Privacy Policy

Effective Date: 20/05/2025
Last Updated: 20/05/2025

This website is operated by the founding team behind the Xinora project (“we”, “our”, or “us”). We are currently in a pre-launch, pre-incorporation phase, during which we provide early access to features and collect limited personal data from users who choose to join our waiting list. This Privacy Policy explains how we handle personal data on our website www.xinora.io (the “Site”), in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).A formal legal entity will be incorporated prior to launch, at which point this policy will be updated accordingly.

1. Data Controllers

Until incorporation, the data controllers under the GDPR are the four individual cofounders of Xinora:

• Davide De Caterina
• Emanuele Navas
• Moritz Benecke
• Luca Garbi

For all privacy-related inquiries, please contact:
Email: d.decaterina@xinora.io

2. Personal Data We Handle

We may handle the following types of personal data through our Site:

• Waiting list submissions: Full name and email address, submitted voluntarily by users wishing to receive updates.
• Demo usage: When a user submits a public LinkedIn profile URL into our demo tool, the system temporarily processes publicly available data from that profile (such as job title, summary, and experience) in real time to generate a personality profile preview.
• Marketing preferences: Whether the user has opted in to receive promotional emails from us.

We do not collect, store, log, or retain any data extracted via the demo. All such data is processed in-memory and discarded immediately after the session.

3. Purposes and Legal Basis for Processing

‍

3.1  Waiting List Communications

Users who voluntarily join the waiting list may receive ongoing communications about the Xinora product, including launch announcements, feature updates, or invitations to test new functionality. These emails are intended to keep users informed and engaged. Every message includes an unsubscribe link. We do not share email addresses with third parties.

3.2  Marketing Communications

Users who opt in may receive marketing emails from Xinora, including special offers, product promotions, or partner announcements. This type of communication is optional and separate from general product updates. Every marketing message includes a clear unsubscribe link, and users can withdraw consent at any time.

3.3  Demo Feature

When a user pastes a LinkedIn URL, the tool retrieves only publicly accessible information, processes it on the fly, and displays an estimated personality profile. This feature exists solely to illustrate the capabilities of our software. No personal data from third-party LinkedIn profiles is stored, retained, reused, or shared.

4. Data Sharing

We do not sell, rent, or trade personal data. If we work with trusted service providers to operate the Site (e.g., email list management), they will only access data under strict data protection agreements and solely for the purposes specified.

We may disclose information if required by law or legal process.

5. Data Retention

• Waiting list data (name and email) is retained only as long as necessary to send product updates or until a deletion request is received.
• Data processed via the demo feature is not retained at all — it is handled temporarily in the browser session and immediately discarded.

6. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right to access;
• Right to rectification;
• Right to erasure;
• Right to restriction of processing;
• Right to data portability;
• Right to object to processing;
• Right to lodge a complaint with a supervisory authority.

To exercise any of these rights, contact us at d.decaterina@xinora.io .

7. Security Measures

We implement reasonable technical and organizational safeguards to protect personal data submitted through the Site. Please note, however, that no internet transmission is ever 100% secure.

8. Cookies

At this time, our Site does not use any cookies for tracking, analytics, or advertising purposes. Should this change, we will update this Policy and notify users via a cookie banner on first visit.

9. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted here with an updated effective date. Once Xinora is formally incorporated, this document will be revised to reflect the new legal entity and controller information.

10. Contact

For any questions about this Privacy Policy or your personal data, please contact:
The Xinora Founding Team
Email: d.decaterina@xinora.io