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) or the United Kingdom, 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”).
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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 Notice 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 Online Terms of Use which incorporates this Privacy Notice.
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.
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 Notice.
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 Notice, 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 Notice, illegal activities, fraud, security or technical issues, misuse
of the Services, or other misconduct, or to enforce our Terms of Use or this Privacy
Notice; 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 Notice.
- 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 Notice.
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. View additional information for participants in the EEA or UK.
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 Notice
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We may make changes to this Privacy Notice 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 Notice 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.
