Privacy Policy

Last Modified: September 18, 2025

SJ MedConnect, Inc. (“Thalamus” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (this “Policy”).

This Policy describes how we collect, use, and share personal information of (1) consumer users of the Thalamus website located at https://thalamusgme.com and all other websites and mobile sites where this Policy appears or is linked (collectively, the “Website”) and (2) consumer users of our products and services (together, the “Services”).

This Policy applies to personal information that we collect:

·       From you directly.

·       Through the Website or any of the Services.

·       In electronic messages between you and any of our personnel or any automated agents enabled through the Website or any of the Services.

·       When you interact with our advertising on third-party websites and services, if that advertising includes links to the Website or the Services where this policy governs.

This Policy does not apply to information collected by:

·       By our affiliates or subsidiaries, separately from us.

·       Any third party, including through any application or content that may link to or be accessible from or through the Website or Services.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE WILL TREAT YOUR INFORMATION. IF YOU DO NOT AGREE WITH THIS POLICY, YOUR CHOICE IS NOT TO USE THE WEBSITE OR THE SERVICES. BY ACCESSING OR USING THE WEBSITE OR ANY OF THE SERVICES, YOU AGREE TO THIS POLICY. THIS POLICY MAY CHANGE FROM TIME TO TIME   (SEE UPDATES TO THIS PRIVACY POLICY). YOUR CONTINUED USE OF THE WEBSITE OR ANY OF THE SERVICES AFTER WE MAKE CHANGES TO THIS POLICY IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THIS POLICY PERIODICALLY FOR UPDATES.

TABLE OF CONTENTS

1.           Personal Information We Collect

2.           How We Use Your Personal Information

3.           How We Share Your Personal Information

4.           Your Choices Regarding Your Personal Information

5.           Security Of Your Personal Information

6.           Retention of Personal Information

7.           International Users

8.           Children and People with Difficulty Accessing

9.           Do Not Track

10.         Updates To This Privacy Policy  

11.         Contact Us

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1.           Personal Information We Collect

We collect personal information about you in several different ways:

Personal Information Collected from You.  When you use the Website or any of the Services, we collect information (a) by which you or your household may be personally identified, related, or described and (b) that is reasonably capable of identifying you or your household when we combine it with other information (collectively, “personal information”). Personal information may include the following categories, depending on how you use the Website or any of the Services and how you communicate with us:

·       Individual identifiers, such as name, username, and date of birth;

·       Contact information, such as mailing address, phone number, and email address;

·       Commercial information, such as products or services purchased, obtained, or considered;

·       Communications with us, preferences, and other information you provide to us, such as any messages, (including via online chat feature), opinions and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other information that you share with us when you contact us directly (such as for customer support services);

·       Autobiographical information you add to your user profile, including images, videos, and other files;

·       Images, data, graphics, video, or other files you upload to participate in community features, such as forums, and other parts of the Services that enable you to communicate with us or with other users;

·       Application information, such as educational background, medical school and licensing exam transcripts, Educational Commission for Foreign Medical Graduates (ECFMG) certifications, personal statements, letters of recommendation, Medical Student Performance Evaluations (MSPEs), deans’ letters, and other professional references;

·       Personal financial and billing information;

·       Association of American Medical Colleges (“AAMC”) ID number, ACGME ID number, and/or similar educational service ID numbers, including but not limited to SFMatch and National Resident Matching Program (NRMP) ID numbers;

·       Data that is personal to your interview and travel planning to enable us to facilitate personal interviews and travel scheduling;

·       Additional information to facilitate participation in voluntary surveys and to conduct contests in connection with our Services; and

·       Additional information as otherwise described to you at the point of collection or pursuant to your consent.

Sensitive Information.  We may need to collect or process personal information that is deemed “sensitive information” or “sensitive data” under certain laws. We may process the following categories of sensitive information when you use the Website or any of the Services:

·       Geolocation data, such as your physical location if you have enabled location services on your device;

·       Authentication data, such as account personal information and login credentials, including unique identifiers like account number and password;

·       Racial or ethnic origin information;

·       Social Security number; and

·       Citizenship and immigration status.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website of third parties (collectively, “User Contributions”). You User Contributions are posted on the Website and transmitted to others at your own risk. Although you may be able to set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that you User Contributions will not be viewed by unauthorized persons.

Information We Collect Automatically.  The Website and Services may automatically collect the following categories of usage and technical personal information about you. This personal information is used by Thalamus for the operation of the Website and Services, to maintain quality of the Website and Services, and to provide general statistics regarding use of the Website and Services. This personal information may include:

·       IP address, which is the number associated with the service through which you access the Internet, like your ISP (internet service provider);

·       Date and time of your visit to or use of the Website and Services;

·       Domain server from which you use the Website and Services;

·       Type of computer, web browsers, search engine, operating system, and platform from which you use the Website and Services;

·       Data identifying the web pages you visited prior to and after visiting the Website or using our Services;

·       Your movement and activity within the Website and Services, including screen recordings, including but not limited to what elements of the Website and Services you use and other users you interact with; and

·       Mobile device Information, including the type of device you use, operating system version, and the device identifier.

The technologies we use for this automatic data collection may include:

Cookies.  We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website.

Web Beacons.  Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Device Identifiers.  When you access the Website by or through a mobile device (including but not limited to smart phones or tablets), we may access, collect, monitor, and/or remotely store one or more “device identifiers,” such as a universally unique identifier, which are small data files or similar data structures. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Website. Some features of the Website may not function properly if use or availability of device identifiers is impaired or disabled.

Third-Party Use of Cookies and Other Tracking Technologies.  Some content or applications, including advertisements, on the Website may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information, including that they may collect your information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Information We May Receive from Third Parties.  We may collect additional personal information about you from third-party websites, social media platforms, and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide the Website and Services to you, to manage your account, to maintain our customer/visitors lists, to provide feedback, for authentication purposes, for service improvement, to provide updates and announcements, to help prevent fraud, and for marketing and advertising purposes.

This Policy only applies to personal information collected by the Website and Services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the personal information that they may collect. You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content. As you are using the Website and 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.

Further, as part of their use of the Services, and subject to the administrator’s determination that such data sharing is permitted under the third party’s terms of use, administrators of residency programs may pull applicant data directly from third parties that they have access to, including the Electronic Residency Application Service (ERAS) and the Accreditation Council for Graduate Medical Education (ACGME), and provide this personal information to Thalamus. We may also receive Information from the AAMC.

You may also separately provide personal information to websites, retailers, or other commerce, product, or service providers through which we provide access to register for the Website and Services.  Depending on the particular promotion, when you register for the Website and Services 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.

Additional Information.  If you choose to transmit additional personal information on the Website or through the Services that is only optional for you to provide to us, we will collect that personal information that you provide and use it in the same manner as other of your personal information that you provide to us. 

Information About Third Parties.  You shall not provide us with personal information regarding another individual unless you have their permission to do so.  Providing personal information about another individual without their consent could be viewed as a data privacy violation and could subject you to sanctions. 

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2.           How We Use Your Personal Information

Generally, we may use your personal information in the following ways and as otherwise described in this Policy or described to you at the time we collect the personal information from you:

To Provide the Website and Services and Personalize Your Experience.  We use personal information about you to provide the Website and the Services to you, to personalize your experience with the Services, to manage your account, and to respond to your inquiries and questions and provide customer service.

Transactions.  We use your personal information to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing.

Changes.  We use your personal information to notify you about changes to the Website or to any Services.

Improvement of the Services.  We may use your personal information to maintain, improve, customize, or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business or the Services, resolve technical problems, improve security, or develop other products and services. 

Creating Deidentified or Other Anonymous Data.  We may create de-identified or other anonymous data from personal information we collect. We make personal information into de-identified or other anonymous data by removing information that makes the data personally identifiable to you.  We may use this de-identified and other anonymous data and share it with third parties for our lawful business purposes as permitted by law.

Company Operations.  We may use personal information for our day-to-day operations, including for employment and administrative purposes and for security, company systems, compliance, and database use.

Marketing.  We may use your personal information in connection with sending you, and permitting our third-party advertisers to send you, marketing communications, including by mail and email, and interest-based (behavioral) advertising, in each case as permitted by law.

Third-Party Relationships.  We may use your personal information to manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, parents, affiliates, subsidiaries, and business partners.

Compliance and Protection.  We may use any of the categories of personal information described above to:

·       Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

·       Protect our, your, and others’ rights, privacy, safety, and property (including by making and defending legal claims);

·       Audit our internal processes for compliance with legal and contractual requirements and internal policies;

·       Enforce the terms and conditions that govern the Website and the Services; and

·       Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

With Your Consent.  If you provide us with express consent or expressly instruct us to share your personal information with a third party, we may do so.

We may also use personal information we receive from partners such as the AAMC to provide Services to you and for data analysis and research that we share with other users of the Services and the general public. Additionally, we may provide your personal information to our partners to provide other users of the Services with selected offers. In addition to marketing and advertising, our partners may use your personal information for services that include, but are not limited to, verification, validation, reference, lookup, risk mitigation and data enhancement. We may also use your personal contact information to contact you to further discuss your interest in the Services, to send you 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.

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3.           How We Share Your Personal Information

We may disclose de-identified or anonymous information about our users, and information that does not identify any individual, without restriction.

We may disclose all categories of your personal information described above with the following categories of third parties:

Affiliates.  We may share your personal information with our affiliates for purposes consistent with this Policy.

Third-Party Service Providers.  We may provide your personal information to third-party service providers that help us provide you with the Website or any Services and to operate our business (for example, web services operators and credit card billing partners). We may also provide your personal information to third-party service providers who may serve you with marketing communications or interest-based (behavioral) advertising as described in this Policy. We sometimes utilize third-party service providers to help us track analytics information. We may disclose your personal information to track your movement and use of the Services. Such data may be stored and analyzed for purposes of internal analysis by Thalamus.

Survey Data.  Any of your personal information collected via survey will be used only by Thalamus unless we specify otherwise when we ask you to participate in a survey. However, we may share aggregate survey information with third parties.

Partner Organizations.  We may provide certain of your personal information to our partner organizations (1) to perform data analysis and product development or improvement; and (2) for research, which may involve provision of your personal information to collaborators, contractors, and researchers.

Professional Advisors.  We may provide your personal information to our lawyers, accountants, bankers, and other outside professional advisors in the course of the services they provide to us.

Corporate Restructuring.  We may share some or all of your personal information in connection with, or during negotiation of, any merger, financing, acquisition or dissolution, transaction, or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires Thalamus or our business or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information described in this Policy.

Other Disclosures.  We may disclose your personal information if we believe in good faith that such disclosure is necessary for any of the following:

·       In connection with a legal investigation;

·       To comply with relevant laws or to respond to subpoenas or warrants served on Thalamus;

·       To protect or defend the rights or property of Thalamus or users of the Website or Services; and/or

·       To investigate or assist in preventing any violation or potential violation of the law, this Policy, or our Website terms of service or other agreement between you and us.

Third-Party Websites.  The Website or the Services may contain links to third-party websites. When you click on a link to any other website or location, you will leave the Website or the Services and go to another website, and another entity may collect your personal information from you. We have no control over, do not review, and cannot be responsible for these outside websites or their content or any collection of your personal information after you click on links to such outside websites. The links to third-party websites are for your convenience and do not signify our endorsement of such third parties or their products, content, websites, or privacy practices.

With Your Consent.  If you provide us with express consent or expressly instruct us to share your personal information with a specific third party or type of third party, we may do so.

Use and Disclosure of Sensitive Information.  Notwithstanding the foregoing to the contrary, we do not collect, use, or disclose your sensitive information beyond the purposes authorized by the applicable law. Accordingly, we only use and disclose your sensitive information as reasonably necessary and proportionate:  (i) to perform the Services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of the Services; (v) for compliance with our legal obligations; (vi) with our service providers who perform the Services requested by you on our behalf; and (vii) for purposes other than inferring characteristics about you.

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4.           Your Choices Regarding Your Personal Information

You have several choices regarding the use of your personal information through the Website and Services:

Email Communications.  We may periodically send you emails that directly promote the use of the Website or Services. When you receive such emails from us, you may indicate a preference to stop receiving further emails, and you will have the opportunity to “opt out” by following the unsubscribe instructions provided in the email you receive or by emailing us directly at privacy@thalamusgme.com.  Despite your indicated email preferences regarding promotions, we may still send you important Services-related communications, including notices of any updates to this Policy or the Website terms of service.

Text Messages.  You may sign up to receive text messages from Thalamus or third-party service providers on behalf of Thalamus (e.g., text message marketing). By using the Website and Services, signing up for text messaging services, or otherwise opting in to receive text messages (opting in via short code or entering your phone number into a Website collection widget), you agree that you have provided Thalamus or its third-party service providers with prior express written consent to be contacted by text message, including recurring automated promotional and personalized marketing text messages.

·       By providing prior express and/or prior express written consent, you agree to receive text messages under the Telephone Consumer Protection Act and related state laws, including using an automatic telephone dialing system (“ATDS”) to deliver text messages to the mobile phone number which you provided to Thalamus. While you consent to receive messages sent using an ATDS (or “autodialer”), the foregoing shall not be interpreted to suggest or imply that any or all of Thalamus mobile messages are sent using an autodialer.  We will use the personal information provided by you in connection with the text messaging services in accordance with this Policy. Your consent is not a condition of any purchase or use of the Services and your consent to be contacted as described is voluntary. The number of text messages you receive may vary based upon the text messaging service(s) you sign up for. Message and data rates may apply.

·       You may revoke your consent and opt out to discontinue text messages at any time. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed).

Cookies.  If you decide at any time that you no longer wish to accept cookies from the Website for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Website or all functionality of the Services. If you have any questions about how to disable or modify cookies, visit https://www.allaboutcookies.org/.

Disclosure of Your Information for Third-Party Marketing Communications.  If you do not want us to share your personal information with third parties for their marketing communications to you, you can directly unsubscribe from their marketing communications by following the unsubscribe instructions in those marketing communications or by emailing us at privacy@thalamusgme.com as applicable.

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5.           Security Of Your Personal Information

Thalamus is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

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6.           Retention of Personal Information

We will retain your personal information for as long as necessary (a) for the purposes for which we have stated that we will use it, as set forth in Section 2 above and (b) to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted to us. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information.

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7.           International Users

Please note that the Website and the Services are hosted in the United States. If you use the Website or any of the Services from outside the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States. The data protection and privacy laws of the United States may differ from the laws in your country. By using the Website or any of the Services, you consent to the transfer of your personal information to the United States.

8.           Children and People with Difficulty Accessing

The Website and the Services are not intended for children under 18 years of age. No one under age 18 shall provide any personal information to or on the Website or the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any personal information on this Website or through any of the Services. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 18, please contact us at privacy@thalamusgme.com.

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information.

Individuals with disabilities who are unable to usefully access the Policy online may contact us at privacy@thalamusgme.com to inquire how they can obtain a copy of our policy in another, more easily readable format.

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9.           Do Not Track

We currently do not support the Do Not Track browser setting or respond to Do Not Track signals.  Do Not Track (or DNT) is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you. For more details about Do Not Track, including how to enable or disable this preference, visit http://www.allaboutdnt.com.

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10.           Updates To This Privacy Policy

We reserve the right to change this Policy at any time. If we make any changes to this Policy, we will post the revised version to the Website and update the “Last Modified” date at the top of this Policy. If we make material changes to this Policy, we will notify you of the changes by email or by posting a notice to the home page of the Website, which in each case will provide you with an opportunity to accept or reject those material changes (note that if you choose to reject the material changes, you must immediately cease your access and use of the Website and all Services). 

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11.           Contact Us

Our contact information is as follows:

SJ MedConnect, Inc. dba Thalamus

548 Market Street, PMB 15342

San Francisco, CA 94104-5401, USA

Email: privacy@thalamusgme.com