Non-US Privacy Disclosure
Dated: June 08, 2023
These privacy disclosures (these “Disclosures”) provide information on collection and use of data about individuals located in a Relevant Country (as defined below).
In these Disclosures,
These Disclosures apply only to In-scope Processing. Please note that, depending on the situation, some of the Harvard activities described below may in the given case not constitute In-scope Processing as that term is used in these Disclosures.
Further, these Disclosures apply only to the Harvard Entities that link to these Disclosures or expressly adopt them in writing. In these Disclosures the words “we,” “us” or “our” refer to LabXchange (“LXC”). In some cases, a Harvard Entity or other Harvard unit may provide other information about its In-scope Processing in its own supplemental or separate disclosures.
These Disclosures concern In-scope Processing by any means, including electronic means (such as websites and mobile applications).
We use the Personal Data that we collect as described in more detail below. The ways in which we collect and use your data vary depending on the relationship between you and us. The following sections of these Disclosures describe in more detail how and why we collect and use Personal Data in various circumstances that may involve In-scope Processing.
As is true of most digital platforms, we obtain certain data automatically when you use one of our websites or mobile applications, such as your IP address, browser type and device type. Certain web-forms also collect Personal Data you provide, for example when you enter data into form fields. If we also process data through our websites or mobile applications for one of the activities described further below, those descriptions will provide additional information about how those data are collected and used. We and our third-party vendors use this Personal Data for the primary purposes of conducting analytics, improving our websites, responding to your requests and providing you with relevant information including program offerings that we believe may be of interest.
The following are examples of the information we collect:
We process your Personal Data collected on our websites and mobile applications:
We process your Personal Data for the purposes described above consistent with the legal bases recognized by the Relevant Law in each Relevant Country, which may include, for instance: enabling you to register for our Services; to provide our Services in accordance with our contract with you (i.e. our Terms of Service); to facilitate transactions requested by you and meet our contractual obligations (for example, registering you for events); to pursue our legitimate interests (for example, website analytics); as necessary for compliance with a legal obligation (for example, responding to a subpoena); or on the basis of your consent, where applicable.
As part of our In-scope Processing, we may obtain certain Personal Data about you from third party sources, which we may use for the purposes and in the ways described in “How We Collect and Use Personal Data” above and in “Additional Uses of Personal Data” below. In some cases, we may obtain your consent for additional uses.
We use partners and service providers such as: edX, Facebook/Meta, Google, Amazon Web Service, etc. that provide analytics and platform support and services for us. Some of these partners have access to Personal Data about you that we may not otherwise have (for example, when you sign up directly with that provider) and may share some or all these data with us.
Some of our online offerings or research activities may allow you to register and login through a third-party platform. When you login to our offering or activity through a third-party platform, you allow us to access and collect any Personal Data from your third-party platform account permitted under the settings and privacy statement of that platform.
We may receive Personal Data from third-party sources, such as public or private databases (for example, compilations of email or postal addresses) and publications (for example, news reports), or companies or institutions that may sponsor or facilitate your participation in one of our programs, which we may also add to existing Personal Data.
In addition to the uses described above, including under “How We Collect and Use Information” and “Personal Data We Obtain from Third Party Sources,” we may use your Personal Data for the following purposes. These additional uses may under certain circumstances be based on your consent, or may be necessary to fulfill our contractual commitments to you, for legal compliance, or to pursue our legitimate interest in the following activities:
We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures, in accordance with Relevant Law and the legal bases for acquiring the data.
For example, we may generally retain Personal Data as follows:
Consistent with the foregoing guidance, some data may be retained indefinitely.
We share your Personal Data with third parties in the ways described in these Disclosures, including the “How We Collect and Use Personal Data” section above, as well as between Harvard Entities. Additionally, we may share information as described below:
We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:
We may also use services provided by third parties (such as social media platforms) to serve targeted ads or sponsored content on third-party platforms.
We may disclose your Personal Data to legal or government regulatory authorities as required by law. We may also disclose your Personal Data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine that disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.
Much of our Personal Data processing takes place in the United States, though sometimes we or third parties with whom we share data may process data in other countries. The data protection laws in the United States and other countries may provide less protection than such laws in your Relevant Country. In the event we transfer your Personal Data outside your Relevant Country as part of our In-scope Processing, we rely where required on appropriate or suitable safeguards or specific legal provisions permitting such transfers under the Relevant Law.
When transferring Personal Data from a country in the European Economic Area (EEA) or from the United Kingdom (UK) to a country outside the EEA and the UK, we may base such transfers on contracts containing legally authorized data protection clauses referred to as Standard Contractual Clauses. You may request a copy of the Standard Contractual Clauses relevant to any such transfer of your Personal Data by contacting us as set forth in the “Contact Us” section below.
Whenever you visit or use our websites or online services, we may deploy cookies and related technologies (“Cookies”) to collect certain personal information about you. We use the information in order to enhance and personalize the experience, to help provide our services, to analyze website and service usage, and to help improve the websites and our related services. To find out more about cookies, visit https://www.internetcookies.org/ .
Third parties may also use Cookies embedded in our sites to collect information about your online activities over time and across different websites you visit. This information may be used by third parties to provide advertising tailored to your interests on other websites, apps and services you visit.
You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies, or you can opt out of the collection and use of some Cookies through tools like the Network Advertising Initiative opt-out page. If you disable or delete certain Cookies in your settings, you may not be able to use features of our websites.
We may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects information using Google Analytics, please see www.google.com/policies/privacy/partners/, and for how to opt out, please see https://tools.google.com/dlpage/gaoptout .
The opt-outs described above may not work for all browsers or devices.
If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.
To the extent required by Relevant Law, upon your reasonable and good faith request, we will inform you whether we hold any of your Personal Data as part of our In-scope Processing. With respect to your Personal Data collected and used in our In-scope Processing, under the Relevant Law you may also be able to:
To submit a request, please send an email message to EEADisclosuresInquiry@harvard.edu. Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we may need to ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.
If our In-scope Processing as to your Personal Data is solely based on your consent, in certain cases you may also have the right under a Relevant Law to withdraw your consent to our processing. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures, or otherwise limit our use of your Personal Data or request its deletion, we may no longer be able to provide you some or all of the related services.
Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent or requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may need to retain certain data to comply with an independent legal obligation, for achieving the lawful purposes for which we obtained the data, or for such reasons as keeping our services and operations safe and secure or safeguarding our rights or the rights or safety of others.
If you have any complaints regarding our privacy practices, you may be able to make a complaint to your national data protection authority, supervisory authority, or other legal authority.
Text, images, simulations, video, audio, audiovisual, graphical, interactive, and other kinds of content and files, along with information about the content that will aid its use and discovery on the Site (collectively, “Resources”), are available from various sources, including Users, for use in the Services. The Services also include comments, messages between users and within groups, responses to assessments, notes, likes, feedback, and other kinds of content posted or provided by Users in connection with the Services (collectively, “Comments” and, together with Resources created or provided by Users, “User Content”).
Please remember that any Personal Data you submit or post as user-generated content in these circumstances could in some cases be seen by others or become public. You should exercise caution when deciding to disclose your personal, financial, or other information in such submissions or posts. We cannot prevent others from using that information in a manner that may violate these Disclosures, the law, or your personal privacy and safety. We are not responsible for the results of such postings.
For more information on User Generated Content, specifically License Grants, Representations, and Warranties, please see our Terms of Service.
We may update these Disclosures from time to time without prior notice by posting revised Disclosures. You can determine when these Disclosures were last revised by checking the Last Updated date at the beginning of these Disclosures.
Representatives in the European Union:
If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us in the following ways:
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