Bellicum understands how important the privacy of personal information is to our customers. Bellicum is committed to honoring your privacy, and to offering special protections for any personal health information you choose to share with us. The document you are reading is our privacy policy for our Web site that is accessible by consumers, and it describes what information we may collect about you, what uses we may make of it, how you can tell us what to do with your information, and what precautions we take against unauthorized access or use of your information.

About this Privacy Policy

This privacy policy applies only to our Web site that may be used by consumers and that provides health care information and services.

• Bellicum.com (www.Bellicum.com) is our Web site. It is open to professionals and non-professionals alike. Bellicum.com may provide peer-reviewed articles, reference tools, medical and clinical information and resources, medical news, medical conference coverage, treatment updates, and certified continuing education for healthcare professionals. It also has tools intended only for the use of a trained healthcare professional.

 Bellicum is also the name we use to refer to our entire company, even though our formal corporate name is Bellicum Pharmaceuticals, Inc. When we refer to ourselves as "we" or "Bellicum", we mean our company, Bellicum Pharmaceuticals, Inc., including any subsidiary that we control (for example a subsidiary that we own). We may share information among our subsidiaries that we own or control, but it is always protected under the terms of this privacy policy.

This privacy policy only applies to Bellicum Web sites. You should read the privacy policy at each Web site that you visit after you leave one of our sites. We are not responsible for how other Web sites treat your privacy, once you leave an Bellicum site.

As our privacy policies change in significant ways, we will make every effort to notify you of the changes. Minor changes to the policy may occur that will not affect our use of individually identifiable health information. When the privacy policies change in a way that significantly affects the way we handle personal information, we will not use the information we have previously gathered without obtaining consent from the appropriate individual. We will post privacy policy changes on our Web sites in a timely manner.

In this section of our privacy policy, we discuss the different types of information we may collect about you, and the ways in which we collect them.

Visitors to each of our Web sites can access the Web site's home page, and browse some areas of the site, without disclosing any personally identifiable information. We do track information provided to us by your browser, including the Web site you came from (known as the "referring URL"), the type of browser you use, the time and date of access, and other information that does not personally identify you.

Customers registering for services on our Web sites are asked to provide us with identifying information, such as name, gender, contact information, and other identifying information. On our registration screen, we clearly label which information is required for registration, and which information is optional and may be given at your discretion. You will also be given a choice about whether or not you want to receive newsletter information. Bellicum Web sites will ask for the customer's consent before collecting personally identifiable information.

We may also collect information about physicians or other healthcare professionals who register on our Web sites from other sources in order to verify their licensure status and identity. In some cases we may ask customers for information after they register, such as credit card information. Where necessary (for example, to process an order for a purchase), our Web sites may contact financial or credit organizations to confirm customer credit cards

• Discussion Boards: When you are using a discussion board on our Web sites, you are posting a message and your user name, which is available for all registered users to see. When you are posting publicly, any user of our web site can see your message. You should not post any information you want to keep private to a discussion board or other public forum on our Web sites.
• Tools: On some of our Web sites, we offer health assessment tools that ask you to provide self-assessment information. Our tools may provide you with the option of storing health information you provide over time on our servers. Some of our tools may not allow storage of information. We will always make it clear to you when information you provide to us through a tool will be saved.
• Member Lookup: When you are registering as a member of some of our Web sites, you may have a choice about whether or not you want other members to be able to look you up and send you messages. If you opt not to be listed, no other members will be able to look you up.
• Additional Forms and Emails: We may also ask you to provide additional information after you register if you want to obtain additional services or information or to resolve complaints or concerns.

In addition, we gather information about you that is automatically collected by our Web server, such as your IP address and domain name. Bellicum will use this information to personalize its offerings and presentations to you, facilitate your movements throughout our Web sites, provide personalized services, and to communicate with you individually.

When you register for a Continuing Medical Education ("CME") activity through our Web site, we collect certain personally identifiable information from you such as your name, email address and mailing address. In addition to personally identifiable information, we collect aggregated non-personally identifiable information about the activities undertaken by our users. We use the information that we collect through CME activities in several ways:

1. Bellicum works with organizations accredited by the Accreditation Council for Continuing Medical Education ("ACCME") to provide continuing medical education for physicians. The ACCME accredited entity, is required periodically to submit aggregated data about CME participants and the CME activities they certify. We also provide personally identifiable information to other accredited CME providers who certify CME activities posted on Bellicum, as required by the ACCME and other accrediting bodies. These reports may include personally identifiable information about you and credits issued to you, for the purpose of maintaining records that you can request from the accredited provider for up to six (6) years;
2. Commercial supporters of CME activities on our Web site will receive only aggregated data about CME activities that are relevant to their interests and/or the courses they support;
3. Bellicum Editorial and Customer Support Staff will have internal access to files containing personally identifiable information, including evaluation forms and aggregated CME participant information. These files can be accessed in order to respond to your questions or comments. Our staff may also use personally identifiable information, including registration information and evaluation data, in assessing educational needs and planning marketing activities; and

We may use the information we collect as otherwise permitted in this Privacy Policy.

Cookies are a technology used by the Bellicum Web site to identify a user as the user moves through the Web site. Your browser allows us to place some information on your computer's hard drive that identifies the computer you are using. We use cookies to personalize our Web site and to track your usage across all of our Web site.

Your Web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, Web sites that are cookie enabled will not recognize you when you return to the Web site, and some Web site functionality may be lost. The Help section of your browser will tell you how to prevent your browser from accepting cookies.

Although cookies do not normally contain personally identifiable information, if you are a registered user we may associate your registration information with cookies our Web site places on your computer's hard drive. Associating a cookie with your registration data allows us to offer increased personalization and functionality. For example, you can elect to have our Web sites "remember" your user name and password and bypass the sign-in process on each visit to the site. Without cookies, this functionality would not be possible.

Some of our business partners may use cookies on our site (for example, advertisers.) We have told them that we do not want them to use cookie information to track our customer's activities once they leave our site. However, because of the way advertisements are served on our Web site, we do not have total control over how advertisers use cookies on our Web site. If you become aware that an Bellicum advertiser is placing an unwanted cookie on your hard drive, please contact us webmaster@Bellicum.com so that we may assist you in resolving the problem.

Bellicum's Web sites are designed and intended for use by adults, and are not intended for, nor designed to be used by children under the age of 18. Minors under the age of 18 may register for our Web sites that collect or present personal healthcare information only with the prior written consent of their parent or legal guardian, and then only under the direct supervision of that parent or guardian. The parent or guardian is responsible for providing supervision to ensure the minor's authentication information is kept secure and the credibility of the health record is maintained. We do not collect personally identifiable information from any person we know is a child under the age of 13.

In this section of our privacy policy, we identify the ways we may use information about you that we have collected.

We create aggregate data about visitors to our Web sites for product development and improvement activities. We also use it for market analysis. We may provide information from our Web sites in aggregate form, with identifying information removed, to third parties. For example, we may tell a health care partner what percentage of our registered users resides in a particular geographical area. When aggregated health information is provided, we pool it from many individual records and strip it of any data that could be used to identify an individual before it is used. Any third party that receives aggregated health care data must agree not to attempt to re-identify the people it belongs to. Depending on our agreement with the third parties, we may or may not charge for this information.

We may target our advertising or marketing depending on information we have about you. Although in no case will the advertiser have access to any individually identifiable information about you. We use information for our own internal marketing, research, and related purposes.

In addition to aggregate information (discussed previously), we may share some kinds of information with third parties as described below.

• Other Companies: We have strategic relationships with other companies who offer products and services on our Web sites. When you are interacting with those companies, different rules and privacy policies may apply. We do not control the collection or use of information you provide to those companies, but we do require that those companies clearly state their policies so you can decide whether to give them any information.
• Companies and People Who Work for Us: We may contract with other companies and individuals to help us provide services. For example, we may host some of our Web sites on another company's computers, hire technical consultants to maintain some aspect of our Web services, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed health care professionals. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. We require all such companies to comply with the terms of our privacy policies, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us. We use our best efforts to limit the use of other companies in areas where personally identifiable healthcare information may be involved.
• Promotional Offers: Sometimes we send offers to selected groups of customers on behalf of other businesses. When we do this, we do not give that business your name and address. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional offers. For example, we may provide an opt-in box for consumers to receive an email from another business, and we make clear that by opting in you are submitting your data to a third party.
• Business Transfers: If we transfer a business unit (such as a subsidiary) or an asset (such as a Web site) to another company, we will require them to honor the applicable terms of this privacy policy.
• Legal Requirements: We may release account and other personal information when we believe release is required to comply with law. We may release personal health information, including information from a medical record, if, in our judgment after review by an attorney, the release is compelled by law or regulation, or if the release is necessary to prevent the death or serious injury of an individual.

When we share information with third parties, we ask that they agree in writing to abide by Bellicum's privacy policies.

If we discover that a third party inadvertently disclosed personal information about any of our customers, we will take immediate action to prevent further occurrences.

Other than the cases described above, Bellicum will not release personally identifiable information to a third party without the customer's consent. Also, if we ask your consent to release personal healthcare information to a third party, we will use our best efforts to clearly define and limit the scope of your consent.

In this section of our privacy policy, we discuss the security measures we take to protect information that we have collected about you.

We have implemented technology and security policies, rules and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also protect your information by requiring that all our employees and others who have access to or are associated with the processing of your data respect your confidentiality.

Bellicum uses security methods to determine the identity of its registered users, so that appropriate rights and restrictions can be enforced for that user. Reliable verification of user identity is called authentication. Bellicum uses both passwords and usernames to authenticate users. Users are responsible for maintaining their own passwords.

Personally identifiable health information you share with us is stored on our database servers at Bellicum data centers or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy. We have a firewall to prevent individuals from accessing information without authorization. Data centers are physically secure and protected from unauthorized access by unauthorized persons. Physical access to the servers requires individual authorization and authentication.

Information in our data centers is backed up routinely, in order to aid in the recovery of information in the event of accidental damage of information or due to a natural disaster. The backup media is stored in a physically secure storage facility.

In this section of our privacy policy, we tell you how to obtain and correct information we have about you, and how to choose what types of information you may share with us.

If you believe that non-medical registration information collected by our Web site(s) is in error, you may edit your personal profile any time that you like. You can directly edit your user profile on our Bellicum.com site. Requests for deletion of your record may result in your removal from the registry, but we may keep certain demographic information about you for product improvement purposes. You may contact us at webmaster@Bellicum.com and ask for the changes that you would like to make.

Bellicum employees and consultants are required to keep customer information private, as a condition of their employment or association with the company. Only selected, authorized Bellicum personnel are permitted to access your health information.

Employees and consultants are required to sign a confidentiality agreement. All employees and contractors must abide by our privacy policy, and those who violate that policy are subject to disciplinary action, up to and including termination of their employment and legal action.

For privacy questions or concerns about one of Bellicum's Web sites, please contact info@Bellicum.com

Our uniform advertising and editorial policy for our web sites that can be accessed by consumers can be found is as follows:

• We may obtain revenues from third parties related to advertising and health information content sponsored by others on our Web site, including advertising revenues, commissions on consumer purchases, fees based on consumer use of links to other Web sites, and revenues for transfer or use of information about users, including aggregate data.
• We do not intend any links to other Web sites, logos, or marks of other companies, or any co-branding to constitute recommendations unless we specifically indicate that we recommend them.
• We will disclose any cases where we have placed health information content on our health Web site because of sponsorship or other support from a third party. In addition to identifying the sponsor, we will clearly disclose significant relationships between the commercial sponsor and our health information content by identifying the sponsor's involvement with that content. We will also disclose whether we have reviewed such content or are posting it as a service to our members for a fee or through some other arrangement.
• For health information content on our Web sites, we will clearly disclose the author or source of the material and the date of the material or its last update. Where we present health information content as the result of clinical experience or scholarly research, we will clearly disclose the actual author of the health information content and others who have had a substantial role in writing, editing or otherwise preparing the material. Where we create health information content for use by consumers, we will provide consumers general information about our authors and their qualifications, our editorial policy, and any expert review process.
• We require authors who write for us to complete a conflict of interest form that requires disclosure of any financial interests and affiliations that may influence, or have the appearance of influencing, the specific content they provide. If the conflicts, in our judgment, are significant, then we require their public disclosure in connection with the content on our Web site. We require the same of those who serve on our various editorial boards.
• We will not make claims of therapeutic benefit without reasonable support, or deliberately provide false or misleading information. Where we offer self-assessment tools, we will disclose their source and appropriately describe the scientific basis for their operation. We will also describe how we maintain self-assessment tools, including a description of any formal evaluation process and the date of the last review or update.

At Bellicum, we have always clearly separated the editorial content and process from advertising. Advertising spaces such as banners and badges are clearly marked. Likewise, any content provided by an advertising sponsor is clearly marked as such, and is physically separated from editorial content. We are also selective in the advertising we accept. Our advertising policies are as follows:

• We will clearly distinguish advertising from health information content, using identifying words, design, or placement. We will design our health Web sites to avoid confusion between advertising and health information content.
• Advertising on Bellicum.com will comply with the laws and regulations of the United States of America, the country in which the site is based. Any other Bellicum sites established in partnership within any other country will also comply with the laws of the country in which the site is established and maintained. We will comply with existing federal and state laws regarding any promotions, rebates, or free or discounted offers on our health Web site.
• Bellicum will have sole discretion for determining the types of advertising that will be accepted and displayed.
• Under no circumstances will Bellicum's acceptance of an advertisement be considered an endorsement of the product(s) advertised or the company that manufactures it.
• Bellicum retains the right to reject advertising of any kind, and will not accept advertising that, in Bellicum's opinion, makes unsubstantiated claims of therapeutic benefit for particular products or contains false or misleading information. In addition, Bellicum will not accept advertising in any form for any products or services known to be harmful to health (e.g., tobacco products), nor knowingly accept advertisements or grants of any kind from companies that manufacture such products directly or through their subsidiaries.
• Bellicum maintains a clear separation between editorial and advertising process and decision making; current or potential sponsors may not dictate the form or substance of the editorial content appearing on the Bellicum site. Bellicum's editors have full responsibility for ensuring compliance with the entire Bellicum advertising policy.
• Bellicum readers should be able to readily distinguish between promotional and editorial material. Toward this end, Bellicum will not run "advertorial" content that is not clearly identified as such.
• Advertisers must respect the terms of our privacy policy, and may not attempt to individually identify any users of our Web sites or obtain inappropriate access through other technological means to personally identifiable information.
• Advertisers will not influence the way any search results for specific information by keyword or topic are displayed on Bellicum. Bellicum will post all of the variables used to determine relevance ranking and the order of search results presented to Bellicum.com readers. Bellicum reserves the right to feature original Bellicum material or content within search results, and any such hierarchy of search results will be free of any influence from advertisers. However, we will target advertising or sponsored health information content to users based on information about them or their use of our Web site, including searches they conduct.

Terms of Use

Our terms of use agreements can be found here.

Revision date: This policy was last updated on February 20, 2006.