THELMA DOES NOT SELL YOUR PERSONAL DATA UNDER ANY CIRCUMSTANCES.

Effective: October 30, 2023

Thelma was designed with privacy and transparency in mind. We care deeply about the psychological safety of the coaching environment. As such, whether you are a coach providing services on our platform, a user of our platform, an entity that contracts on behalf of users of our platform, or a visitor to our website, we want you to know how we collect, use and share your data. We want to communicate this in plain language, as much as possible.

Privacy Policy Table of Contents

1. Introduction and Definitions

2. What Data We Collect

3. How We Use Data

4. How We Share Data

5. Your Choices, Rights and Obligations

6. Other Important Information

1.Introduction and Definitions

This privacy policy describes our privacy practices relevant to the Site, Services and Platform and the impact these practices have on Applicants, Site Visitors, Coaches and Users. Each term is defined below. Let’s start with a brief overview of what we do, how and where we might be collecting data and then define some relevant terms.

Thelma offers parents quality coaching through a variety of behavioral techniques and methods (the “Services”) through our online platform (the “Platform”). People to whom we provide Services directly via the Platform we will refer to as “Users”.

We also collect data from parenting coaches (“Coaches”) who typically contract with us to provide services to Users via the Platform and from visitors (“Visitors”) to our website www.mythelma.com (the “Site”).

2. Data We Collect

2.1 Data You Provide to Us Data From Our Website If you are a visitor to our public website, MyThelma.com and its subdomains, we and trusted third parties acting on our behalf will collect certain information. We use cookies and similar technologies (e.g., web beacons, pixels and ad tags) to collect data (e.g., device IDs) from our public Site to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Site. We also allow third parties to use cookies as the Cookie Policy describes, including to assist in our marketing and advertising campaigns. We may also collect (or rely on others who collect) data about your device where you have not engaged with our Site (e.g., ad ID, IP address, operating system and browser data) so we can provide our Visitors with a better user experience. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

Data From Coaches

If you are a Coach, we collect data when you submit an inquiry to provide coaching services for us, when you use the Platform, when you request technical support, and when you otherwise initiate communication with us. We never require Coaches to provide us any sensitive Personal Data (e.g. financial data), although we may request demographic or other personal data from Coaches when we are testing a new tool or feature, staffing a specific program for customers, or conducting research studies. The type of demographic or personal data we may request may include gender, race, ethnicity, specialized skills such as ASL, or for federal programs, your citizenship. When asking for demographic data, Thelma does so because we believe it will improve the services for our Users and Coaches; however, providing such personal information shall remain optional. We may ask for your consent as a Coach to record your coaching session for training, research, or additional purposes as further described below, in which case we may collect data capturing your image, voice, and/or a transcript of recording in order to conduct analysis for the betterment of the User, also known as our Members, and your future coaching sessions. Thelma understands video recordings may capture sensitive personal information; therefore where possible, Thelma will minimize the amount of personal data being accessed by analyzing the recordings after de-identification or conducting analysis on the transcript rather than the full video. We discuss this further below. As a Coach, we may ask you to provide us data to improve your experience on the Platform. For example, we may ask Coaches: to review your coaching and Platform experience AND personal preferences within your Coach profile, such as preferred pronouns and preferred language In all circumstances, your decision to provide Thelma with Personal Data has no impact on your role as a Coach, and you may withdraw consent at any time by emailing. info@thelma.com.

Data From Users

If you are a User, we collect data when you register for the Platform and when you access the Services via the Platform. We require certain Personal Data in order to register your account, such as: ·Your name ·Your email address ·Your phone number ·Your role or title ·Your Country and State (where applicable) We require this data for at least the following reasons: 1) to create your account; 2) to ensure you are matched with a coach in an appropriate time zone; 3) ensure we have minimum location data to honor your specific privacy rights; and 4) to ensure you receive coaching from a coach who expertise matches your needs.

We collect data to provide and improve your experience on the Platform. For example, we may ask Users to: ·complete surveys to help us match you with a Coach that aligns with your coaching goals. ·review your coaching and Platform experience. ·enter your personal preferences within your User or Coach profile, such as preferred pronouns and preferred language To facilitate a robust and meaningful coaching experience, both you and your Coach will have access to your matching survey and assessment responses.

We collect usage data from Users accessing the Platform, such as which programs you respond to and attend, your session ratings, when you attend a coaching session, and any other usage data you share with us in connection with the Platform.

2.2 Aggregated Data from Use of Platform

Whether you are a Coach or User, we may aggregate and de-identify the data related to your use of the Platform apart from what has been detailed above. We may analyze your usage data and content when it is uploaded, sent, received, or stored. We may use your data, activity logs, and direct feedback to improve our Platform and Services.

2.3 Cookies and Similar Technologies

First, while we use similar technologies within our Platform, they are separate and apart from the cookies and similar technology used on our public website, MyThelma.com. In order to provide specific functionality within our Platform, there is limited use of tracking technology within our Platform.

2.4 Your Device and Location

We do collect data from Platform Visitors such as data about your device and location via IP address, the type of browser you use, amount of time you spend on the Platform, pages viewed, forms submitted, and the digital channel that brought you to the Platform. Thelma will not request precise geo-location data from our Users. If you access the Platform via a mobile device, we may collect data such as the first time the mobile application is opened, mobile carrier, and the type of device that is being used.

2.5 Audio & Video Data

We may record coaching sessions on the Platform with the express consent of both Coach and User (each a “Recording”). If you have consented to a Recording, it will be used to inform analyses on the quality and effectiveness of your coaching session. The session recording may be used in the following ways: · Analysis of aggregate call statistics such as number of speaker turns · Text analysis including full transcript, key words, themes, and sentiment of words · Audio analysis ·

Thelma is constantly looking for ways to level up our services, to find a way to use the behavioral sciences to improve your coaching journey. Occasionally in our pursuit of the best tools to provide the analysis we need to serve our Users, we may use third party vendors to assist with analyzing this data. When working with third party vendors, Thelma’s priority is to provide data in a deidentified manner and will ensure that your data remains confidential to your experience with Thelma. Thelma requires all third party vendors to certify in contract they will never sell data and will maintain strict privacy and security controls for all data they may have access to as a result of working with Thelma. Occasionally, the third party vendors providing analysis of this data may utilize Artificial Intelligence. That means, in addition to the contractual protections noted above, any data received from Thelma cannot be used to train their algorithms or data models and must be immediately deleted after providing the requested analysis. Any data shared with our third party vendors remains encrypted in transit. The Recordings will be securely stored in our data center in the United States and our employees can access them on a need-to-know basis only.

2.6 Health Information

Thelma’s Services do not collect any Protected Health Information as that is defined under the Health Insurance Portability and Accountability Act (“HIPAA”) and the use of our Services does not require HIPAA compliance. Additionally, Thelma is not considered a Covered Entity under HIPAA.

3 How We Use Your Data

3.1 Services

Thelma believes that no parent should have to navigate challenges alone, and we seek to provide the highest level of service and guidance to parents. To do so, Thelma will use your data to drive these insights and analytics to serve you, our Users. The primary manner in which we use all data is to provide the Services and help us improve the Site, the Platform, and the quality of our Services, and this extends to Personal Data. As described in Section 2, we request sensitive Personal Data only under very limited circumstances, providing it is always voluntary, and you may revoke permission at any time.

3.2 Communicate With Users and Coaches

We require certain Personal Data from both User and Coaches for routine communication with each and to facilitate the relationship between them.

3.3 Market To You As further described in the Cookie Policy and in Section 2 above, we collect certain data from Site Visitors for marketing and advertising purposes. Site Visitors may also need to provide data to schedule a demo or interact with a bot on the Site to get what information you need from us more efficiently.

3.4 Provide Customer Support

You may provide data via the Site or Platform that we use to provide a better customer support experience to you. For instance, if you were to email info@thelma.com our team would request specific information for verification purposes and as necessary to address your concerns.

3.5 Generate Insights That Do Not Identify You

Most data that we use internally is de-identified and aggregated. This includes any research we conduct to understand the parenting landscape better.

4 How We Share Data with Third Parties AS REFERENCED ABOVE, THELMA DOES NOT SELL YOUR PERSONAL DATA.

We share certain Personal Data about Users with Coaches (and vice versa) such as contact information and responses to surveys to facilitate the ability for Coaches to provide services to Users.

5 Your Choices, Rights and Obligations

5.1 Data Retention We store Personal Data for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

5.2 Your Choices About Email Subscriptions

You may opt out of receiving email communications from us by following the unsubscribe link within those communications or by emailing us at info@mythelma.com.

5.3 Your Choices About Promotional Communication

If you are outside of the European Union (“EU”), you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at info@thelma.com. If you opt out, we may still send you non-promotional communications specifically related to your use of the Platform.

5.4 Your Jurisdiction-specific Rights

A. Your Rights under State level privacy laws At this time, the United States is seeing a handful of states passing comprehensive privacy legislation. We understand each state is doing their best to protect the individual privacy rights for their own citizens, which is why Thelma has taken the approach of honoring all privacy rights such as the generally accepted principles of right of access, deletion, and correction for all our Users, and will honor the rights described within this Privacy Policy as well as all rights afforded you under your local state laws.

B. Your Rights under the California Consumer Privacy Act (“CCPA”) If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and ask us not to sell it. You may request what personal information we have about you. If you make this request, we will return to you: (i) The categories of personal information (as defined by the CCPA) we have collected about you. (ii) The categories of sources from which we collect your personal information. (iii) The business or commercial purpose for collecting or selling your personal information. (iv) The categories of third parties with whom we share personal information. (v) The specific pieces of personal information we have collected about you. (vi) A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact. (vii) A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with. If you request we delete your data pursuant to the CCPA, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through deidentification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate. We will not discriminate against you under any circumstances for exercising your rights in connection with the CCPA. To exercise your California data protection rights described above, please send a request to info@thelma.com

6 Other Important Information

6.1 Thelma coaching recommendations.

We are currently using computer algorithms to deliver suggested coach matches for our members. These Services rely on User actions and inputs including Your decision to accept or reject the proposed coaches. Thelma believes that responsibly designed technology will enhance the coaching experience. Thelma recognizes the use of these technologies can raise new privacy and security concerns. This is why, for example, Thelma allows you to contact us at any time to receive a full list of coaches.

6.2 Thelma’s Commitment to Children’s Privacy

At Thelma we take children’s privacy very seriously. The Platform and Services are designed for individuals over the age of 18 and we do not intentionally collect any data from persons under the age of 18 (each a “Child”). If you believe that Thelma may have directly collected personally identifiable information about a Child and wish to have us remove that Personal Data, please contact us at info@thelma.com to let us know.

6.3 How Do You Communicate Changes to This Privacy Policy?

If we make changes to this Privacy Policy, we will notify you by revising the date at the top of the policy. In some cases, such as a material change in our practices, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Site, Platform or Services to stay informed about our data practices and the ways you can help protect your privacy.

6.4 How Can I Contact Thelma About This Privacy Policy?

Please email us at info@thelma.com