Effective Date: April 6, 2023
Cullinan Oncology, 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:
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:
We may use Personal Information (and Sensitive Personal Information) to:
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 email@example.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:
We may use this Information to:
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 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.
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:
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 your Personal Information when we are legally permitted to do so, for example, when we have established a legal basis such as:
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.
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 firstname.lastname@example.org. 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 Oncology, Inc.
If you have any questions about a Cullinan clinical trial that you are participating (or have participated) in, please contact the Study Site directly.