(6 August 2020)
This Privacy Notice explains what information Harvard Business School Online collects from you, through our interactions with you, how we use that data, and when and with whom we share it.
The information you provide to Harvard Business School Online allows us to provide you with access to a specific program or other service, to administer that service and to keep you updated on that service and our other services.
If you are located in the European Economic Area (EEA), you can find more information about your data subject rights.
Please send any questions about this Notice or about Harvard Business School Online's handling of your information to hbsonlineprivacy@hbs.edu.
SCOPE
Harvard Business School Online is a unit of Harvard Business School. This Notice applies to information that we collect through our websites and other services (collectively, the “Services”).
NATURE, USE AND DISCLOSURE OF INFORMATION
Information we collect
We collect information, including Personally Identifiable Information when you sign up for a user account, download an application, participate in our online programs, or otherwise communicate with Harvard Business School Online. Personally Identifiable Information means your full name and other information that personally identifies you.
We may also collect, use, store, and share certain usage information and system identifiers and metadata.
How we use the information we collect and reasons we share it
Harvard Business School Online uses the information we collect to deliver our programs and Services. We may also use the information to communicate with you about the Services and to give you updates about Harvard Business School Online and other Harvard programs.
We share the information with your consent or as necessary to provide a service you have requested. For example, we share some of your information with Harvard Business School Online faculty and staff, and other participants in your program can view your profile and username and comments. We also share with a limited number of third-party contractors who perform certain functions on our behalf. For example, we work with a third party who helps us with participant support queries.
Comments or other information posted or contributed by you to any part of a service designed to be visible to the public or to other Harvard Business School Online participants may be viewed and downloaded by others who use or access the service. Please bear this in mind when you post such comments or other information.
OTHER IMPORTANT PRIVACY INFORMATION
Below you will find additional privacy information you may find important.
Use for personalization and pedagogical improvements
Links to other applications and websites
Security
Consent to processing outside home country
Collection of data from children
Your California privacy rights
Changing our Privacy Notice
(8 January 2019)
This Privacy Policy explains what information Harvard Business School Online collects from you, through our interactions with you, how we use that data, and when and with whom we share it.
The information you provide to Harvard Business School Online allows us to provide you with access to a specific program or other service, to administer that service and to keep you updated on that service and our other services.
If you are located in the European Economic Area (EEA), you can find more information about your data subject rights here.
Please send any questions about this Policy or about Harvard Business School Online's handling of your information to hbsonlineprivacy@hbs.edu.
SCOPE
Harvard Business School Online is a unit of Harvard Business School. This Policy applies to information that we collect through our websites and other services (collectively, the “Services”).
NATURE, USE AND DISCLOSURE OF INFORMATION
Information we collect
We collect information, including Personally Identifiable Information when you sign up for a user account, download an application, participate in our online programs, or otherwise communicate with Harvard Business School Online. Personally Identifiable Information means your full name and other information that personally identifies you.
We may also collect, use, store, and share certain usage information and system identifiers and metadata.
How we use the information we collect and reasons we share it
Harvard Business School Online uses the information we collect to deliver our programs and Services. We may also use the information to communicate with you about the Services and to give you updates about Harvard Business School Online and other Harvard programs.
We share the information with your consent or as necessary to provide a service you have requested. For example, we share some of your information with Harvard Business School Online faculty and staff, and other participants in your program can view your profile and username and comments. We also share with a limited number of third-party contractors who perform certain functions on our behalf. For example, we work with a third party who helps us with participant support queries.
Comments or other information posted or contributed by you to any part of a service designed to be visible to the public or to other Harvard Business School Online participants may be viewed and downloaded by others who use or access the service. Please bear this in mind when you post such comments or other information.
OTHER IMPORTANT PRIVACY INFORMATION
Below you will find additional privacy information you may find important.
Use for personalization and pedagogical improvements
Links to other applications and websites
Security
Consent to processing outside home country
Collection of data from children
Your California privacy rights
Changing our Privacy Policy
Effective Date: 8 January 2019
(23 May 2018)
This Privacy Policy explains what information HBX collects from you, through our interactions with you, how we use that data, and when and with whom we share it.
The information you provide to HBX allows us to provide you with access to a specific program or other service, to administer that service and to keep you updated on that service and our other services.
If you are located in the European Economic Area (EEA), you can find more information about your data subject rights here.
SCOPE
HBX is a unit of Harvard Business School. This Policy applies to information that we collect through our websites and other services (collectively, the “Services”).
NATURE, USE AND DISCLOSURE OF INFORMATION
Information we collect
We collect information, including Personally Identifiable Information when you sign up for a user account, download an application, participate in our online programs or otherwise communicate with HBX. Personally Identifiable Information means your full name and other information that personally identifies you.
We may also collect, use, store and share certain usage information and system identifiers and metadata.
We may collect information about participant performance and patterns of learning. In addition, we may track information indicating, among other things, which portions or pages of a Service were visited, the order in which they were visited, when they were visited and which hyperlinks and other user interface controls were used.
We may collect, use, store and share a variety of information, including IP address, operating system, unique IDs of cookies, unique IDs sent from mobile devices, network carriers or data providers, device types, browser types, version and language, Internet Service Provider (ISP) information, referring and exit websites and applications, attributes of computer or device usage, date/time stamps, click-through URLs, information contained in HTTP headers or other internet transfer protocol signals, clickstream data and other similar data, for each user of a Service or any HBX program, and we may be able to determine your geographic location (or the location of your device or ISP) with such data. Various web analytics tools are used to collect this information. Some of the information may be collected through cookies, pixel tags, scripts, log files, web beacons and other similar technologies, which are further described here.
Most browsers and mobile devices offer instructions on how to disable cookies (typically in “Preferences” or “Settings”). If you disable our cookies, some functions and conveniences of a service may not work properly or at all.
We may use, store, aggregate and disclose some or all of the data we collect from you and other users of the Services for the purposes set out in this Policy.
How we use the information we collect and reasons we share it
HBX uses the information we collect to deliver our programs and Services. We may also use the information to communicate with you about the Services and to give you updates about HBX and other Harvard programs.
We share the information with your consent or as necessary to provide a service you have requested. For example we share some of your information with HBX faculty and staff and other participants in your program can view your profile and username and comments. We also share with a limited number of third party contractors who perform certain functions on our behalf. For example we work with a third party who helps us with participant support queries.
Comments or other information posted or contributed by you to any part of a service designed to be visible to the public or to other HBX participants may be viewed and downloaded by others who use or access the service. Please bear this in mind when you post such comments or other information.
We may collect, use, process, store and share the information about you in the following ways
- To authenticate your identity; to process payments, subscriptions, credits and refunds; and to collect amounts owed, as applicable.
- To respond to a specific inquiry or provide you with access to the specific service, program content and/or Services or reports you select.
- To provide, administer, maintain, improve, individualize and evaluate the Services and other HBX Services and offerings, both individually and in the aggregate. This may include sharing information with HBX faculty, staff, administrators, moderators, leaders, facilitators, and others who are involved in performing these functions for us, as well as with other third parties in some circumstances as described below.
- To provide or conduct the Services by sharing information about you (including Personally Identifiable Information) with other participants in an HBX program or other Service in which you are participating. This may include, for example, sharing comments, course work, reflections, images, video clips, “stars,” “likes,” and other content that you submit, contribute, upload, post or distribute on a Service (collectively, “Contributions”) with other such participants, along with your name, user name, photo, geographic location (city, state and country only), and other potentially identifying information, and providing other such participants with other information from your profile that you have elected to share or that we otherwise may disclose consistent with FERPA to the extent FERPA applies.
- To create and publish a participant directory accessible by other participants in the program or other Service in which you are participating.
- To disclose or provide Directory Information to third parties or the public, unless you have opted out of such disclosure by contacting hbxprivacy@hbs.edu. For a description of information we define as Directory Information and for additional information regarding FERPA, see http://hbx.hbs.edu/ferpa. Unless you have opted out, we may disclose or publish Directory Information whether or not it is subject to FERPA.
- To share information with a collaborating college or university with which you are associated, including, for example, those listed at Collaborating Colleges & Universities, regarding your HBX application and participation in the Services.
- To link or combine information provided by you or collected about you via the Services with other information provided by you or collected about you by HBX, the Harvard Business School or Harvard University or any of their partners.
- To perform research – for example, academic, scientific, educational or business research.
- To send you notices, updates, announcements and communications (whether by email, phone, text or SMS messages, pop up notifications, or other similar methods) about the Services, or about other programs, services, products, events, opportunities or activities offered by HBX, Harvard Business School or Harvard University, or selected educational or business partners, that may be of interest to you.
- To enable HBX, Harvard Business School and Harvard University to do marketing, promotions and advertising, either directly or through third parties. These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content would be of interest to you.
- To assess admissions criteria and to track both individual and aggregate attendance, progress, performance and completion of an online program or use of the Services, and to analyze statistics on participant performance and how participants learn.
- To conduct cross device matching, whether probabilistic or deterministic, in order to identify connections between devices such as smart phones, computers, tablets or other network connected devices or physical objects.
- To maintain and improve the functioning and security of the Services and our software, systems and network.
- To enable service providers or contractors to perform certain functions on our behalf, including, without limitation, analytics and information processing; processing transactions, subscriptions or other payments; providing, operating or administering a Service or part of it; providing or updating content for any of the Services; or in connection with other aspects of our Services, or in order to integrate with other products or services.
- To share your Contributions with third parties or with the public, in ways not otherwise permitted under this Privacy Policy, if (1) we have eliminated your name and photo from your Contributions, (2) you have submitted Contributions to a portion of a Service that is open to non-participants, or (3) we otherwise are permitted to disclose your Contributions under FERPA to the extent FERPA applies.
- To provide opportunities for current or future participants in the Services or other HBX offerings, who may have interests or educational goals similar to yours, to communicate or work with you.
- To respond to subpoenas, court orders, or other legal process; in response to a request for cooperation from law enforcement or another government agency; to investigate, prevent or take action regarding actual or suspected violations of our Terms of Use or this Privacy Policy, illegal activities, fraud, security or technical issues, misuse of the Services, or other misconduct, or to enforce our Terms of Use or this Privacy Policy; as otherwise may be required by applicable law; or to protect our rights, property or safety or those of others.
- To report to your employer on your progress and participation in a Service if your participation in the Service is sponsored by your employer, and if you have so consented or we are otherwise permitted to do so.
- To share aggregated, anonymized information with the public and with third parties, including but not limited to researchers and business partners.
- To achieve any purpose described elsewhere in this Privacy Policy.
- To achieve any purpose to which you have consented at the point of collection of information or at another time.
- To achieve any other purpose permitted by law (including, without limitation, disclosures permitted under FERPA, to the extent FERPA applies to the information).
OTHER IMPORTANT PRIVACY INFORMATION
Below you will find additional privacy information you may find important.
Use for personalization and pedagogical improvements
We aim to provide current and future users of each service with the best possible
educational experience. We may conduct research intended to enhance HBX’s instructional
offerings and the quality of learning and related sciences more generally. To further
these goals, we sometimes present different users with different versions of program
materials and software. We do this to personalize the experience to the individual
learner (assess the learner's level of ability and learning style, and present materials
best suited to the learner), to evaluate the effectiveness of our program materials,
to improve our understanding of the learning process, and otherwise to improve the
effectiveness of our offerings and teaching and learning more generally. We may publish
or otherwise publicize results from this process, but will only share Personally Identifiable
Information as otherwise permitted under this Privacy Policy.
Links to other applications and websites
A service may contain links to websites and mobile applications published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of HBX. These other websites and applications are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites and applications. We encourage you to be aware when you are redirected to a third-party website or application and to review the privacy policies and terms of use of each website and application you visit and use.
Security
HBX has a program designed to protect Personally Identifiable Information in its possession or control. This includes a variety of privacy and security policies, processes and procedures, including administrative, physical and technical measures. Nonetheless, no method of collection, storage or transmission is entirely secure, and we cannot guarantee that our security measures will be effective.
Consent to processing outside home country
You understand and unambiguously consent to the collection, use, disclosure and retention of information in the United States and other countries and territories, for the purposes set forth in this Privacy Statement and the HBX Terms of Use or such other terms of use as may be provided for the applicable service. You consent to the collection, use, disclosure and retention by HBX of your Personally Identifiable Information and other information as described under this Privacy Statement, including but not limited to the transfer of your Personally Identifiable Information or other information between HBX and the third parties and affiliates described in this Privacy Statement. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable Personally Identifiable Information to a jurisdiction which may provide a different level of privacy protection than that available in your own country. Participants in the EEA please see here.
Collection of data from children
Our Services are generally not intended for users under the age of 18. We do not knowingly collect personal data from anyone under 13 years of age. From time to time, we may offer certain Services to users under 18 years of age (but 13 years of age or older). In those cases, we may have additional requirements for registration or access, including, for example, approval of a parent or other authorized person. If we become aware that a person under 13 years of age has registered, we will delete any Personally Identifiable Information of such person from our records.
Your California privacy rights
If you are a California resident, you may request information about our disclosure
of personal information to third parties or affiliated companies for their direct
marketing purposes. To obtain this information, please contact us as set forth in
the “Contact Us” section. Please include sufficient personal identification information
so that we can process the request, including that you are a California resident.
Please also note that this information will be provided only once per calendar year.
Changing our Privacy Policy
We may make changes to this Privacy Policy at any time, but will alert you that we
are doing so by giving notice via the Services or by some other means. By registering
for, accessing or using any of the Services after any changes have been made, you
signify your agreement to the modified Privacy Policy and all of the changes, which
will be effective immediately unless we notify you of a later effective date. If the
changes are not acceptable to you, you should discontinue use of the Services.
Effective: 23 May 2018
(26 August 2016)
This Privacy Policy applies to information that HBX collects through the hbx.hbs.edu and myhbx.org web domains and other websites, applications, programs, and online or mobile products and services of HBX (collectively, the “Services,” and each a “Service”). By registering for, downloading, accessing or using any of the Services, you accept and agree to this Privacy Policy, whether or not you are a registered user or have an account.
If you do not want to be bound by this Privacy Policy, do not register for, download, access or use any of the Services. This Privacy Policy does not apply to information that we may collect from you in other ways (for example, the policy does not apply to information that you may provide to us over the telephone, by fax, through conventional mail or electronic mail, or to any information that you may provide to us or Harvard Business School independently of the HBX Services). In addition, please note that your education records are protected by the Family Educational Rights and Privacy Act (“FERPA”) to the extent FERPA applies.
Remember that your use of the Services is at all times subject to the HBX Terms of Use, which incorporate this Privacy Policy.
As used in this Privacy Policy, “we,” “us” and “our” refer to HBX, which is a unit of Harvard Business School.
USERNAMES AND CONTRIBUTIONS
Comments or other information posted or contributed by you to any part of a Service designed to be visible to the public or to other HBX participants may be viewed and downloaded by others who use or access the Service. Please bear this in mind when you post such comments or other information.
CONSENT TO PROCESSING OUTSIDE HOME COUNTRY
You understand and unambiguously consent to the collection, use, disclosure and retention of information in the United States and other countries and territories, for the purposes set forth in this Privacy Policy and the HBX Terms of Use or such other terms of use as may be provided for the applicable Service. You hereby consent to the collection, use, disclosure and retention by HBX of your Personally Identifiable Information (defined below) and other information as described under this Privacy Policy, including but not limited to the transfer of your Personally Identifiable Information or other information between HBX and the third parties and affiliates described in this Privacy Policy. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable Personally Identifiable Information to a jurisdiction which may provide a different level of privacy protection than that available in your own country.
If you choose not to provide us with certain information required to provide you with various programs offered on a Service, you may not be able to establish a user account and we may not be able to provide you with those programs.
PERSONALLY IDENTIFIABLE INFORMATION
As used in this Privacy Policy, “Personally Identifiable Information” means your full name and other information that personally identifies you.
INFORMATION WE COLLECT AND HOW WE USE IT
We may collect information, including Personally Identifiable Information, when you sign up for a user account, download an application, participate in our online programs or communicate with us through the Services. We may also collect, use, store and share certain usage information about participant performance and patterns of learning. In addition, we may track information indicating, among other things, which portions or pages of a Service were visited, the order in which they were visited, when they were visited and which hyperlinks and other user interface controls were used.
We may collect, use, store and share a variety of information, including IP address, operating system, unique IDs of cookies, unique IDs sent from mobile devices, network carriers or data providers, device types, browser types, version and language, Internet Service Provider (ISP) information, referring and exit websites and applications, attributes of computer or device usage, date/time stamps, click-through URLs, information contained in HTTP headers or other internet transfer protocol signals, clickstream data and other similar data, for each user of a Service or any HBX program, and we may be able to determine your geographic location (or the location of your device or ISP) with such data. Various web analytics tools are used to collect this information. Some of the information may be collected through cookies, pixel tags, scripts, log files, web beacons and other similar technologies, which are further described here.
Most browsers and mobile devices offer instructions on how to disable cookies (typically in “Preferences” or “Settings”). If you disable our cookies, some functions and conveniences of a Service may not work properly or at all.
We may use, store, aggregate and disclose some or all of the data we collect from you and other users of the Services for the purposes set forth in this policy.
USE AND DISCLOSURE TO THIRD PARTIES
Among other things, we may collect, use, process, store and share the information about you collected through a Service (including your Personally Identifiable Information) as follows:
- To authenticate your identity; to process payments, subscriptions, credits and refunds; and to collect amounts owed, as applicable.
- To respond to a specific inquiry or provide you with access to the specific Service, program content and/or services or reports you select.
- To provide, administer, maintain, improve, individualize and evaluate the Services and other HBX services and offerings, both individually and in the aggregate. This may include sharing information with HBX faculty, staff, administrators, moderators, leaders, facilitators, and others who are involved in performing these functions for us, as well as with other third parties in some circumstances as described below.
- To provide or conduct the Services by sharing information about you (including Personally Identifiable Information) with other participants in an HBX program or other Service in which you are participating. This may include, for example, sharing comments, course work, reflections, images, video clips, “stars,” “likes,” and other content that you submit, contribute, upload, post or distribute on a Service (collectively, “Contributions”) with other such participants, along with your name, user name, photo, geographic location (city, state and country only), and other potentially identifying information, and providing other such participants with other information from your profile that you have elected to share or that we otherwise may disclose consistent with FERPA to the extent FERPA applies.
- To create and publish a participant directory accessible by other participants in the program or other Service in which you are participating.
- To disclose or provide Directory Information to third parties or the public, unless you have opted out of such disclosure by contacting hbxprivacy@hbs.edu. For a description of information we define as Directory Information and for additional information regarding FERPA, see http://hbx.hbs.edu/legal/ferpa. Unless you have opted out, we may disclose or publish Directory Information whether or not it is subject to FERPA.
- To share information with a collaborating college or university with which you are associated, including, for example, those listed at Collaborating Colleges & Universities, http://hbx.hbs.edu/courses/core/collaborating-colleges, regarding your HBX application and participation in the Services.
- To link or combine information provided by you or collected about you via the Services with other information provided by you or collected about you by HBX, the Harvard Business School or Harvard University or any of their partners.
- To perform research – for example, academic, scientific, educational or business research.
- To send you notices, updates, announcements and communications (whether by email, phone, text or SMS messages, pop up notifications, or other similar methods) about the Services, or about other programs, services, products, events, opportunities or activities offered by HBX, Harvard Business School or Harvard University, or selected educational or business partners, that may be of interest to you.
- To enable HBX, Harvard Business School and Harvard University to do marketing, promotions and advertising, either directly or through third parties. These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content would be of interest to you.
- To assess admissions criteria and to track both individual and aggregate attendance, progress, performance and completion of an online program or use of the Services, and to analyze statistics on participant performance and how participants learn.
- To conduct cross device matching, whether probabilistic or deterministic, in order to identify connections between devices such as smart phones, computers, tablets or other network connected devices or physical objects.
- To maintain and improve the functioning and security of the Services and our software, systems and network.
- To enable service providers or contractors to perform certain functions on our behalf, including, without limitation, analytics and information processing; processing transactions, subscriptions or other payments; providing, operating or administering a Service or part of it; providing or updating content for any of the Services; or in connection with other aspects of our Services, or in order to integrate with other products or services.
- To share your Contributions with third parties or with the public, in ways not otherwise permitted under this Privacy Policy, if (1) we have eliminated your name and photo from your Contributions, (2) you have submitted Contributions to a portion of a Service that is open to non-participants, or (3) we otherwise are permitted to disclose your Contributions under FERPA to the extent FERPA applies.
- To provide opportunities for current or future participants in the Services or other HBX offerings, who may have interests or educational goals similar to yours, to communicate or work with you.
- To respond to subpoenas, court orders, or other legal process; in response to a request for cooperation from law enforcement or another government agency; to investigate, prevent or take action regarding actual or suspected violations of our Terms of Use or this Privacy Policy, illegal activities, fraud, security or technical issues, misuse of the Services, or other misconduct, or to enforce our Terms of Use or this Privacy Policy; as otherwise may be required by applicable law; or to protect our rights, property or safety or those of others.
- To report to your employer on your progress and participation in a Service if your participation in the Service is sponsored by your employer, and if you have so consented or we are otherwise permitted to do so.
- To share aggregated, anonymized information with the public and with third parties, including but not limited to researchers and business partners.
- To achieve any purpose described elsewhere in this Privacy Policy.
- To achieve any purpose to which you have consented at the point of collection of information or at another time.
- To achieve any other purpose permitted by law (including, without limitation, disclosures permitted under FERPA, to the extent FERPA applies to the information).
USE FOR PERSONALIZATION AND PEDAGOGICAL IMPROVEMENTS
We aim to provide current and future users of each Service with the best possible educational experience. We may conduct research intended to enhance HBX’s instructional offerings and the quality of learning and related sciences more generally. To further these goals, we sometimes present different users with different versions of program materials and software. We do this to personalize the experience to the individual learner (assess the learner's level of ability and learning style, and present materials best suited to the learner), to evaluate the effectiveness of our program materials, to improve our understanding of the learning process, and otherwise to improve the effectiveness of our offerings and teaching and learning more generally. We may publish or otherwise publicize results from this process, but will only share Personally Identifiable Information as otherwise permitted under this Privacy Policy.
LINKS TO OTHER APPLICATIONS AND WEBSITES
A Service may contain links to websites and mobile applications published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of HBX. These other websites and applications are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites and applications. We encourage you to be aware when you are redirected to a third-party website or application and to review the privacy policies and terms of use of each website and application you visit and use.
SECURITY
HBX has a program designed to protect Personally Identifiable Information in its possession or control. This includes a variety of privacy and security policies, processes and procedures, including administrative, physical and technical measures. Nonetheless, no method of collection, storage or transmission is entirely secure, and we cannot guarantee that our security measures will be effective.
CHANGING OUR PRIVACY POLICY
We may make changes to this Privacy Policy at any time, but will alert you that we are doing so by giving notice via the Services or by some other means. By registering for, accessing or using any of the Services after any changes have been made, you signify your agreement to the modified Privacy Policy and all of the changes, which will be effective immediately unless we notify you of a later effective date. If the changes are not acceptable to you, you should discontinue use of the Services.
MINORS
Our Services are generally not intended for users under the age of 18. We do not knowingly collect personal data from anyone under 13 years of age. From time to time, we may offer certain Services to users under 18 years of age (but 13 years of age or older). In those cases, we may have additional requirements for registration or access, including, for example, approval of a parent or other authorized person. If we become aware that a person under 13 years of age has registered, we will delete any Personally Identifiable Information of such person from our records.
QUESTIONS OR PRIVACY CONCERNS
If you have questions about this Privacy Policy or privacy concerns regarding the Services or HBX, please contact us at hbxprivacy@hbs.edu.
Effective: 26 August 2016
(2 September 2015)
As used in this Privacy Policy, "we," "us" and "our" refer to HBX.
This Privacy Policy only applies to information that we collect through the HBX Website (the “Site,” which consists of all content and pages located within the hbx.hbs.edu and/or myhbx.org web domains) and does not apply to information that we may collect from you in other ways (for example, this policy does not apply to information that you may provide to us over the telephone, by fax, through conventional mail or electronic mail, or to any information that you may provide to us that we have not requested). In addition, please note that your education records are protected by the Family Educational Rights and Privacy Act (“FERPA”) to the extent FERPA applies.
USERNAMES AND CONTRIBUTIONS
Comments or other information posted or contributed by you to any area of the Site designed to be visible to the public or to other HBX participants may be viewed and downloaded by others who visit the Site. Please bear this in mind when you post such comments or other information.
CONSENT TO PROCESSING OUTSIDE HOME COUNTRY
By using the Site, or providing information to HBX, you understand and unambiguously consent to the collection, use, disclosure and retention of information in the United States and other countries and territories, for the purposes set forth in this Privacy Policy and the HBX Terms of Use. You hereby consent to the collection, use, disclosure and retention by HBX of your Personally Identifiable Information (defined below) as described under this Privacy Policy, including but not limited to the transfer of your Personally Identifiable Information between HBX and the third parties and affiliates described in this Privacy Policy. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable Personally Identifiable Information to a jurisdiction which may provide a different level of privacy protection than that available in your own country.
If you do not agree with these terms, then do not access, browse, or register for the Site or any programs offered through the Site. If you choose not to provide us with certain information required to provide you with various programs offered on our Site, you may not be able to establish a user account and we may not be able to provide you with those programs.
PERSONALLY IDENTIFIABLE INFORMATION
As used in this Privacy Policy, “Personally Identifiable Information” means your full name and other information that personally identifies you.
INFORMATION WE COLLECT AND HOW WE USE IT
We may collect information, including Personally Identifiable Information, when you sign up for a user account, participate in our online programs or communicate with us. We may also collect certain usage information about participant performance and patterns of learning. In addition, we may track information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited and which hyperlinks and other user interface controls were used.
We may log the IP address, operating system and browser software used by each user of the Site or any HBX program, and we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity. Various web analytics tools are used to collect this information. Some of the information is collected through cookies (small text files placed on your computer that store information about you, which can be accessed by the Site). You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies. If you reject our cookies, some functions and conveniences of this Site may not work properly. We may aggregate some or all of the foregoing types of data for the purposes set forth herein.
Information may also be collected through pixel tags or scripts, which are invisible tags placed on certain pages of the Site but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies the pixel tag will simply detect an anonymous website visit.
USE AND DISCLOSURE TO THIRD PARTIES
Among other things, we may use the information about you collected through the Site (including your Personally Identifiable Information) in connection with the following:
- To authenticate your identity and process payments and refunds, as applicable.
- To enable us to provide, administer, maintain, improve, individualize and evaluate HBX offerings, both individually and in the aggregate.
- For individuals who have created a user account and are students or recent graduates from a Collaborating College, to enable us to provide information to such Collaborating College regarding your HBX application.
- For purposes of scientific research - for example, in the areas of cognitive science and education.
- For the purpose for which you specifically provided the information, for example, to respond to a specific inquiry or provide you with access to the specific program content and/or services or reports you select.
- To create and publish a participant directory accessible by other participants in the program in which you are enrolled.
- To enable us to assess admissions criteria and to track both individual and aggregate attendance, progress and completion of an online program, and to analyze statistics on participant performance and how participants learn.
- To monitor and detect violations of the HBX Terms of Use or this Privacy Policy, as well as other misuses and potential misuses of the Site.
- To publish information, but not Personally Identifiable Information unless otherwise agreed to in writing, gathered about HBX access, use, impact and participant performance for marketing, scientific, business or any other lawful purpose.
- To send you updates about online programs offered by HBX or other events, to send you communications about products or services of HBX, Harvard Business School or Harvard University, or selected business partners that may be of interest to you, or to communicate with you about HBX programs, Site maintenance or updates.
- To maintain and improve the functioning and security of the Site and our software, systems and network.
- For purposes described elsewhere in this Privacy Policy (including, for example, sharing information with third parties).
- As otherwise described to you at the point of collection, pursuant to your consent, or as otherwise permitted by law.
We may share information we collect (including Personally Identifiable Information) with third parties for the purposes described above or as follows:
- With service providers or contractors that perform certain functions on our behalf, including, without limitation, processing information that you provide to us on the Site, processing payments via third party providers and other transactions through the Site, operating the Site or portions of it, providing or administering programs, or in connection with other aspects of our services, or in order to integrate with their products or services.
- With other participants in an HBX program or other offering in which you are participating, in order to conduct the program or offering. This may include, for example, sharing comments, course work and other content that you submit, contribute, post or distribute on the Site (collectively, “Contributions”) with other such participants, along with your user name and photo, and providing other such participants with information from your profile that you have elected to share or that we otherwise may disclose consistent with FERPA to the extent FERPA applies.
- With third parties or the public, if (1) we have eliminated your user name and photo from your Contributions, (2) you have submitted Contributions to a portion of the Site that is open to non-participants, or (3) we otherwise are permitted to disclose your Contributions under FERPA to the extent FERPA applies.
- For purposes of scientific research - for example, in the areas of cognitive science and education.
- To provide opportunities for other current or future participants in HBX offerings, who may have interests or educational goals similar to yours, to communicate or work with you.
- To make available directory information about who is participating or has participated in HBX offerings, except insofar as you opt out of such disclosures by the means we provide.
- To respond to subpoenas, court orders, or other legal process; in response to a request for cooperation from law enforcement or another government agency; to investigate, prevent or take action regarding illegal activities, suspected fraud, security or technical issues, or to enforce our Terms of Use or this Privacy Policy; as otherwise may be required by applicable law; or to protect our rights, property or safety or those of others.
- If your participation in a Program is sponsored by your employer, and if you have so consented, or if we are otherwise permitted, to report on your progress and participation in the Program.
- As otherwise described to you at the point of collection, pursuant to your consent, or otherwise as permitted by law (including, without limitation, disclosures permitted under FERPA, to the extent FERPA applies to the information).
In addition, we may share aggregated information that is not Personally Identifiable Information with the public and with third parties, including but not limited to researchers and business partners.
USE FOR PERSONALIZATION AND PEDAGOGICAL IMPROVEMENTS
We aim to provide current and future users of the Site with the best possible educational experience. We may conduct research intended to enhance HBX’s instructional offerings and the quality of learning and related sciences more generally. To further these goals, we sometimes present different users with different versions of program materials and software. We do this to personalize the experience to the individual learner (assess the learner's level of ability and learning style, and present materials best suited to the learner), to evaluate the effectiveness of our program materials, to improve our understanding of the learning process, and otherwise to improve the effectiveness of our offerings and teaching and learning more generally. We may publish or otherwise publicize results from this process, but will only share Personally Identifiable Information as otherwise permitted under this Privacy Policy.
LINKS TO OTHER WEBSITES
The Site contains links to websites published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of HBX. These other websites are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites. We encourage you to be aware when you are redirected to a third-party website and review the privacy policies of each website you visit and use.
SECURITY
HBX has a program designed to protect Personally Identifiable Information in its possession or control. This includes a variety of privacy and security policies, processes and procedures, including administrative, physical, and technical measures. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is entirely secure, and we cannot guarantee that our security measures will be effective.
CHANGING OUR PRIVACY POLICY
Please note that we review and may make changes to this Privacy Policy from time to time. When changes are made, the Privacy Policy link will include a notation “Revised (date)” or similar disclosure, indicating that you should review the new terms. The notation will be included in the Privacy Policy link for at least seven (7) days after the update has been made. Any changes to this Privacy Policy will be effective immediately upon posting on this page, with an updated effective date. By accessing the Site after any changes have been made, you signify your agreement to the modified Privacy Policy and all of the changes. In case you miss the notation described above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.
MINORS
Our Site is not intended for use by minors, and HBX does not knowingly collect personal data from minors, without the approval of a parent or other authorized person. If we become aware that a minor has registered without such approval, we will expunge any related Personally Identifiable Information of such minor from our records.
PRIVACY CONCERNS
If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the information we maintain about you, please contact us at hbxprivacy@hbs.edu.
Effective Date: 2 September 2015