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.
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.
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.
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.
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.
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.
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
4. Disclosures & Transfers.
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;
• 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.
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.
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.
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: firstname.lastname@example.org
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 email@example.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.