Privacy

Notice

Privacy Notice

Effective Date: April 6, 2023

Cullinan Therapeutics, Inc. (“Cullinan,” “our,” “we” or “us”) respects your privacy and we want you to be familiar with how we collect, use, share, or otherwise process, your Personal Information. This Privacy Notice is meant to help you understand our privacy practices related to the Personal Information we collect from you or that you share with us when you visit and interact with us, such as through our website(s), when you participate in our clinical programs, apply for employment, or have other interactions with us (collectively “Services”) where we display or reference this Privacy Notice.

We encourage you to read this entire Privacy Notice.

Personal Information we may collect and use “Personal Information” refers to any information that relates to you directly or indirectly, in particular by reference to an identifier, location or factors specific to physical, physiological, genetic, economic, cultural or social identity. Cullinan may collect and process Personal Information you provide to us directly, indirectly, or in connection with the use of our website(s) or other Services, such as:

  • Business and/or Personal contact information (e.g., name, email address, telephone number, mailing address, etc.)
  • Professional credentials, such as curriculum vitae/resume, employment history, education, specialty, etc.
  • Internet and electronic network activity information or online identifiers, such as information about your interactions with our online resources, IP address, cookies, etc.
  • Inferences we derive from the information that we collect, such as profiles, as permitted
  • Other types of information as necessary to your use of our Services, participation in our Services or to fulfill your requests

In the course of offering our services, and with your consent, where required, we may also collect and process Personal Information that is of a sensitive nature, including, for example the following categories of Sensitive Personal Information:

  • Financial information including bank and account details
  • Race and ethnicity
  • Precise geolocation
  • Information related to your health and medical condition(s), which may include genetic data or biometric information
  • Medical treatments, medications, and test results
  • Information about your insurance

We may use Personal Information (and Sensitive Personal Information) to:

  • Communicate with you, or respond to your communications or requests including questions related to products in development, or in market
  • Recruit candidates for participation in research opportunities, such as clinical studies, or in conducting clinical activities
  • Recruit for employment purposes, new-hire onboarding and other activities in the course of employment with Cullinan, which may include pre-employment screening, scheduling interviews, or communications regarding the application process, benefit administration, payroll, etc.
  • Process and manage safety and quality concerns
  • Provide you with our Services, or support-related activities
  • Develop and manufacture innovative therapies
  • Fulfill our obligations to you under an applicable contract or to conduct business with you
  • Analyze and improve our Services and business processes
  • Conduct surveys, or polls and obtain testimonials
  • Tailor marketing programs, administer retargeting messaging and profiling activities, and send you promotional materials, (e.g., newsletters)
  • Conduct other legitimate business activities, as allowed by applicable law
  • Comply with legal or regulatory requirements

We will only process Sensitive Personal Information when we have your express consent, or as required or permitted under applicable law, for example, when necessary to comply with applicable law, respond to legitimate requests from government authorities, including authorities that may be outside of your country of residence, to protect or defend our legal interests, and if necessary, to protect the safety of our employees and other stakeholders. Please contact us at privacy@cullinantx.com to make a request to opt out of processing of your sensitive information.

The types of Personal Information listed above are not exhaustive and may vary depending on the way that you interact with us or the type of Personal Information that we need to Process for particular activities. In the event, we use Personal Information about you, which is not listed in the Privacy Notice, we will inform you of the information that we use at the time of collection or when we communicate with you.

Other Information we may collect When you visit, use, and interact with our Services, we may collect Personal Information that does not directly identify you but allows us to understand how you interact with our Services. This information may include information about the device and software you use, such as:

  • IP address
  • Web browser type
  • Operating system version
  • Device identifiers

We may use this Information to:

  • Optimize and personalize your interactions with our Services
  • Operate and improve our Services
  • Maintain and secure our Services
  • Enforce our Terms of Service, or other legal rights

Where permitted by law, we may also combine Personal Information collected through our website or online Services with our offline records and information obtained from public or third-party sources. We use this consolidated information to improve our sites, enhance our marketing activities, and to facilitate other business functions. If necessary, we will collect your consent, or provide an opportunity for you to opt out of this type of processing.

Cookies, web server data and other technologies We use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to collect and store analytics and other information when you use our Services, such as our website. The cookies we use include both first-party and third-party cookies. Cookies, or similar technologies, may provide us the following information:

  • The type of web browser software you use
  • The name of the domain from which you access the Internet (including client and server IP addresses, usernames, ports, queries, or other status-related information)
  • The Internet address of the website from which you linked directly to our Services
  • The date and time you access our Services
  • Which pages you have visited on our Services

Cookies may be placed on your computer by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. These cookies can help us to share content from our social media sites, gain helpful insights about how our Services are used and how we can improve your experiences and interactions during your use of our Services.

We use Google Analytics and Google Tag Manager, which uses cookies and similar technologies to collect and analyze information about use of our website and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at Google Analytics Opt-out Browser Add-on Download Page.

Communicating with you We may contact you periodically by email, for example, if you have opted in to receive emails from us, to provide information regarding programs, services and content that may be of interest to you. In addition, some of the features on our website may allow you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via email. You can opt out of these communications by clicking on the "unsubscribe" button at the bottom of promotional email communications, as applicable.

Information we share with third parties We may disclose your Personal Information to third parties for various business purposes as described in this Privacy Notice or under specific circumstances, including:

  • To Service Providers working on our behalf, or providing services such as information technology, website hosting, communication and marketing activities, customer and patient services, and similar services in support of clinical trials, employee recruitment and employment activities
  • Third parties to whom you authorize us to disclose your Personal Information in connection with our Services
  • To authorized law enforcement, regulatory or other government authorities, where required by applicable law, or pursuant to a valid subpoena

When we share data with Service Providers, we require that they use your Personal Information only for the purposes we've authorized, and for the limited reasons explained in this Privacy Notice. We also enter into agreements with these Service Providers to require them to protect your Personal Information appropriately.

How we safeguard your Personal Information Although we cannot guarantee the security of activities, transmissions or communications conducted via the Internet, Cullinan has implemented reasonable physical, technical, and administrative security measures to protect Personal Information collected and used as described in this Privacy Notice.

International transfers of Personal Information Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. We will only permit the transfer of your Personal Information when we are legally permitted to do so, for example, when we have established a legal basis such as:

  • When we must transfer the information to fulfill our obligations under a contract or agreement we have entered with you
  • When we must comply with a legal requirement such as required regulatory filings or reporting
  • For the protection of vital interests of individuals
  • For our legitimate business interests, and for other purposes allowed under applicable laws.

You should not use our Services if you do not want your Personal Information potentially transferred to, or otherwise processed in countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you are located in the EEA, your Personal Information may be transferred to our affiliates or service providers in non-EEA countries that are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures to protect your personal information, such as standard contractual clauses approved by the European Commission.

Children’s Privacy Our Services are not directed at, nor intended for children under the age of 16. We do not knowingly collect information from visitors to this website or users of our Services in this age group. We encourage parents to speak with their children about their use of the Internet and the information they disclose to or make available through our Services. Anyone under 16 years old should seek a parent or guardian’s permission, prior to using our website or disclosing any Personal Information to Cullinan.

Other Websites Our website may contain links to other websites. Cullinan does not endorse, nor are we responsible for the operations or management of those other websites. Please be advised that this Privacy Notice does not apply to your use of those other websites. We encourage you to review their applicable privacy notices, policies, terms of use, etc., to understand how they collect, use and protect Personal Information.

Retaining your Personal Information We will retain your Personal Information for the time period required or allowed by applicable law. Otherwise, we keep your Personal Information for as long as reasonably necessary to serve the purpose(s) for which it was collected.

Exercising your rights Cullinan is committed to respecting your choices about the use of your Personal Information, and we will take reasonable steps to respond to and honor your requests to exercise your rights to access, correct, delete or object to the use, disclosure or other processing of your Personal Information.

In the event we are unable or prohibited from complying with your request, we will inform you accordingly, within the time required under applicable law.

We may need to request additional information about you in order to verify your identity and respond to your request. Be assured that we will not discriminate against you for exercising your rights relating to your Personal Information.

If you have provided permission to Cullinan to process your Personal Information, you have the right to withdraw your consent for such processing at any time by contacting us at privacy@cullinantx.com. In addition, and if you have any unresolved concerns, you have the right to lodge a complaint with the competent data protection authority in your country.

Changes to this privacy notice Cullinan may modify this Privacy Notice at any time, at our discretion. We encourage you to visit this page periodically and to review our most current Privacy Notice and applicable effective date.

How to contact us If you have questions about this Privacy Notice or our privacy practices, or if you wish to submit requests or exercise your rights regarding your Personal Information as provided for by applicable law, please contact us at:

Cullinan Therapeutics, Inc.
One Main Street, Suite 1350
Cambridge, MA 02142
Email: privacy@cullinantx.com

If you have any questions about a Cullinan clinical trial that you are participating (or have participated) in, please contact the Study Site directly.