Harvard Business School Online Privacy Policy

Updated 8 January 2019. For the previous version of this policy, please click here.

Updated 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”).

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Our Services include the web domains online.hbs.edu and myhbx.org and other Harvard Business School Online websites, applications, programs, and online or mobile products and Services of Harvard Business School Online. This Policy does not apply to information that we collect from you in others ways (for example, information that you provide over the telephone, by fax, through conventional mail or email or any information that you may provide to us or Harvard Business School independently of our websites and Services).

Your use of Harvard Business School Online Services is subject to the Harvard Business School OnlineTerms of Use which incorporates this Privacy Policy.

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.

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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 Harvard Business School Online 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

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.

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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 Harvard Business School Online Services and offerings, both individually and in the aggregate. This may include sharing information with Harvard Business School Online 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 a Harvard Business School Online 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 hbsonlineprivacy@hbs.edu. For a description of information we define as Directory Information and for additional information regarding FERPA, see http://online.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 Harvard Business School Online 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 Harvard Business School Online, 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 Harvard Business School Online, Harvard Business School or Harvard University, or selected educational or business partners, that may be of interest to you.
• To enable Harvard Business School Online, 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 Harvard Business School Online 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

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We aim to provide current and future users of each service with the best possible educational experience. We may conduct research intended to enhance Harvard Business School Online'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

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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 Harvard Business School Online. 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

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Harvard Business School Online 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

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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 Harvard Business School Online 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 Harvard Business School Online 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 Harvard Business School Online 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

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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

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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

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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.