Last Updated: [June 1st, 2019]

SJ Medconnect, Inc., d/b/a “thalamus” (“we” or “us”) is committed to protecting your privacy. We want you to know what information we collect and what we do with it. We are dedicated to treating your personal information with care and respect.

This Privacy Policy describes how we collect, store, use and distribute information through any of the Thalamus services, however accessed (the “Service”), our websites, including but not limited www.thalamusgme.com (the “Site”), as well as any related documentation, software and other properties we control (together with the Service and the Site, the “Properties”).

In addition to this Privacy Policy, you should review our Terms and Conditions of Use, available at www.thalamusgme.com/terms/terms.html. We use defined terms in this Privacy Policy relating to the Service that are defined in the Terms and Conditions of Use.

1. Consent.
By using the Service and/or visiting, browsing or using any of our Properties, you consent to the use of your information as described in this Privacy Policy.  You may withdraw your consent to our processing of your Personal Information at any time.  However, withdrawing consent may result in your inability to continue using some or all of the Services.

2. Collection of Information.

The Types of Information We Collect

We have several areas where you can submit information to us, and we also have features that automatically collect information from visitors and users of the Properties. We may collect Personally Identifiable Information (“Personal Information”) and Non-Personally Identifiable Information (“Non- Personal Information”) from you.

This Privacy Policy is primarily concerned with our collection of Personal Information. Personal Information is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, email address, ERAS number and/or ACGME ID. Also, any additional information, to the extent that they are used or provided to Thalamus as part of the Service and can be used to identify you are considered to be your Personal Information and will be protected accordingly. If we charge fees for any of the Services, Personal Information would also include any personal financial and billing information, such as billing name and address and credit card number (“Billing Information”) that you provide.

Non-Personal Information is information that cannot, by itself, be used to identify a particular person or entity and also includes any aggregate information and/or usage information relating to the Services or other Properties that we have gathered, as long as any Personal Information has been removed from it. This policy does not restrict our use of Non-Personal Information and you agree that we may use or transfer any Non-Personal Information that we collect from you or based on your usage, at our discretion. However, if we If we combine Non-Personal Information we collect about you with Personal Information that we collect about you, we will treat the combined information as your Personal Information.

Thalamus is not responsible for verifying the accuracy of any information that you provide or post to the Service or any of our Properties. We may, but are not obligated to, monitor data that you post via electronic software or personnel to check for obscenity, defamation or other types of abusive language or behavior, as well as for content that may infringe our rights or the rights of others, all of which we may remove at any time.

Information You Provide To Us

• Registration and Service Usage Data. When expressing an interest in obtaining additional information about the Services, registering for and/or actually using the Services, we may require you to provide personal contact information, such as your name, address, phone number, ERAS or ACGME ID and email address. You will also be able to add autobiographical information to your personal Service user profile, including images, video and other files. Since our Services include facilitating your personal interview and travel scheduling, you may also be required to input data that is personal to your interview and travel planning.  This information is referred to as your “Personal Contact Information.”

• Commerce Functionality. We may offer premium elements of the Service and/or additional services or products. In that case, we may request that you provide additional billing information, such as a billing address, credit card, PayPal or other billing information (“Billing Information”). Please note that we may also provide product purchase directly to properties that are operated by third parties. Any such third party properties will be governed by their own privacy policies.

• Sharing and Community Features. We may offer features within the Service or other Properties that allow you to further communicate with us or with other users and to participate in community features, such as forums. These features may allow you to additionally upload images, data, graphics, video or other files.

• Surveys, Contests. We may occasionally ask you to participate in voluntary surveys. We may also conduct contests in connection with our Properties, as part of which we may request additional information from you. 

Information We Automatically Collect

As you browse or use our Service (or other Properties), we may use a variety of technologies that automatically or passively collect information about your usage, including but not limited to tracking your movement through the Properties, tracking your device type, operating system, pages served to you, the time of use, what elements of the Service you use and what other users you interact with, your preceding page views and other data related to any session. We may also track and collect information on your and other Users’ IP address and other unique identifiers for your applicable mobile or other device. Collectively, this information is referred to as “Analytics Information.” Some tools that we may use to collect Analytics Information include:

• Cookies. Cookies are small pieces of data that are stored on your computer or mobile device.

• Tags/Pixels/Beacons. These terms are generally used synonymously to describe small blocks of code on webpages that do things like allow another server to measure viewing of a webpage. They are often used in connection with cookies.

• Other. We may use technology available on your device, technology similar to cookies and pixels and technology that is later developed, all for similar purposes.

We may also use these tools within Service related emails that we send to you. We sometimes utilize third party service providers to help us track the activity and user flows within our Properties, using similar tools. Such tracking would track an individual user’s movements but the data would not be tracked in a personally identifiable way. Such data would be stored and analyzed on an aggregated basis for purposes of internal analysis by Thalamus. We may work with advertisers and other third parties whose products or services are promoted on our Properties that may also use similar technologies. In those cases, we advise you to check their privacy policies.

Information We Receive From Third Parties.

There are instances where we may receive information from third parties.

• As part of their use of the Service, Administrators of Programs will pull Applicant data directly from third parties that they have access to, including ERAS and ACGME. When we receive any of your ERAS, ACGME or other personal data via the Service, we will use such data in conformance with the terms permitted by those organizations.

• You may also separately provide information to websites, retailers or other commerce, product or service providers through which we provide access to registration for our Service. Depending on the particular promotion, when you register for the Service through such a promotional partner of ours, that partner may provide us with a user/member name that you already use with that partner’s products or services or that you or it have otherwise pre-selected as part of the promotion.

• As you are using our Services, you may click through certain links or promotions that will enable you to purchase products or use services provided by promotional partners or other sites or commerce providers. Some of those entities may share with us certain information that you provide to them. By clicking through to those links or promotions, you agree to allow us to receive and use any information that you may provide to such entities, under the same terms as if you provided it to us directly.

• We may purchase or otherwise receive data from third parties and add it to our existing user database, to improve our service, to provide pertinent offers in which we think you would be interested or otherwise. Thalamus is not responsible and assumes no liability if another site or commerce provider uses any information about you in violation of its own privacy policy, or applicable law.

3. Use of Information.

We use the information we collect in the following ways:

Information Collected / Use

Registration and Service Usage Information 

We use this information to manage your account, to provide the Service, to maintain our customer/visitor lists, to provide feedback, for authentication purposes, for service improvement, to provide updates and announcements and to address issues like malicious use of the Service. We may also use your Personal Contact Information for limited marketing purposes, namely, we may provide certain elements of your Personal Contact Information to our partners in order to provide users with selected retail and other types of offers.  In addition to marketing and advertising, our partners may use your data for services that include but are not limited to, verification, validation, reference, lookup, risk mitigation and data enhancement (collectively, these are known as “Permitted Partner Uses”). Please note that the limited Personal Contact Information that we provide to our partners for such purposes will never include your ERAS or ACGME ID, personal statements, test scores, grades, or other evaluations of your academic or professional performance.  Users will be subject to all third party privacy rules. We may also use your Personal Contact Information to contact you to further discuss your interest in the Service, to send you information regarding information about us or our partners, to identify your company/organization as a customer, and to use your company/organization’s name and/or logo on our website and in our marketing materials. For our internal purposes, we may retain logs of all comments or messages that you post or send via any facilities that we provide but we will not be obligated to do so.

Any information that you provide directly to another party using the Service (such as to a Program Administrator), even privately, is at your own risk relative to that party and we cannot guarantee that such party will abide by our Privacy Policy or any other code of conduct.

All information you send or post to areas of the Properties that are public or semi-public (such as message boards accessible to all Services users) becomes public information that will not be treated as Personal Information. So please be careful about posting any Personal Information to such areas.

Billing Information 

We use Billing Information solely to check the financial qualifications of prospective customers and to collect payment for premium services or products. We may use a third-party service provider to manage payment processing. This service provider will not be permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on our behalf.

Analytics Information 

Any personally identifying information collected via survey will be used only by us unless we specify otherwise when we ask you to participate. However, we may share aggregate survey or contest result information with others. If we conduct contests or sweepstakes, we will use the information you provide to conduct the contests or sweepstakes and for any other purposes to which you consent. If we offer contests or sweepstakes with our partners, we may notify you that we will share the information we obtain from you with them and will give you the opportunity to choose whether or not to participate at the point where we collect such information.

Information We Receive From Third Parties

We will use this information in accordance with this Privacy Policy.

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled “Amendment of this Privacy Policy”.

4. Disclosures & Transfers.
We have put in place contractual and other organizational safeguards with our agents to ensure a proper level of protection of your Personal Information. In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy. By using the Services, you consent for us to provide certain elements of your Personal Contact Information to our partners for the Permitted Partner Uses. Their use of such information, including targeted promotions, will be subject to our and their privacy policy. If you do not consent to share your information with our partners, you can opt-out of our sharing of such information at any time by sending an email to privacy@thalamusgme.com. In this e-mail, state that you do not want Thalamus to share your Personal Information with third parties for the “Permitted Partner Uses.” Your request will be processed within thirty (30) days of the date of which we receive it. The only third parties with whom we may ever share some of your information are described in the bullet point list of exceptions below.

5. Exceptions.

The following are the entities with respect to whom we may share your information:

• any of our affiliated companies or partners;

• any entity who you give us consent to share your information with;

• companies acting as our agents in hosting, building, developing or otherwise supporting our Properties and in providing our Service, including but not limited to any component thereof (e.g. credit card processing, customer/support services, email providers) to you, all of which agree to use it only for that purpose and to keep the information secure and confidential;

• entities into which our company is merged, or to which a substantially majority of our assets, equity, site or operations have been transferred or merged into (including during any diligence efforts in support of such an action), will be able to use your personal information under the terms of this Privacy Policy. We will notify you if any of these events occur by updating this Privacy Policy and, if practically possible, via other means; and/or

• any entity with whom we are required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency’s request, or in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property.

You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your information to be shared or transferred to third parties without your permission.

6. Security.

The security of your Personal Information is very important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Service, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any computer, laptop, phone, tablet or other device on which you utilize the Service.

7. Sharing Information with Third Parties.

You will be able to share information with third parties through use of the Service and other Properties. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

8. Third Party Widgets and Links.

We may display links to other sites and we may provide tools and widgets from other sites and services, including but not limited to tools that allow you to share, distribute or otherwise publish or make available your travel schedule and plans and/or other Service content via such third party properties. We are not responsible for those other sites and services, their privacy policies or how they treat information about their users. We advise you to check their privacy policies to find out how they are treating your personal information. If you click through any third party links or use any third party tools or widgets you are totally responsible for your data and you agree (i) Thalamus has no responsibility for what those sites or services do with any data of yours and (ii) that you will indemnify Thalamus and its affiliates for any claims that may arise or that you may have in relation to what those sites or services do with your data.

9. Retention.

We will retain your Personal Information for as long as we believe that it remains useful to us for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. Please note that if you request that your information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.

10. Amendment of this Privacy Policy.

We reserve the right to change this Privacy Policy at any time and without prior notice by posting an updated policy within applicable areas of the Service and Properties. If we do, the new terms will take effect at the posted effective date. You should review this policy often, to make sure you have not missed any updates. Additionally, if we believe that any updates reflect material changes to your rights, we will use reasonable efforts to provide additional notice to you, such as by email or by means of a notice on our home page and/or sign-in page that you must view to enter the Service. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

11. Access and Accuracy.

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you, to have a general account of our uses of that information, to limit our uses of your Personal Information, and to request the deletion of Personal Information held about you. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.  If you are a California resident and would like a copy of this notice, please submit a written request to: privacy@thalamusgme.com

12. Contact Us.

You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us by emailing privacy@thalamusgme.com or by writing to us at:

SJ Medconnect, Inc.
77 Alviso Street
Santa Clara, CA 95050

If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.