HBX Privacy Policy

(Revised 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