Privacy Notice

This Privacy Notice (the “Notice”) explains what information LabXchange (“LXC”) collects about you through the LXC services, how we use that data, and when and with whom we share it. The LXC services (the “Services”) are defined in our Terms of Service, which are available at Terms of Service.

The information you provide to LXC allows us to provide you with access to LXC, to provide the Services to you, to administer the LXC website, and to keep you updated on services we provide.

By accessing or using our Services, you agree to our collection and use of information in accordance with this Privacy Notice.

If you are located outside of the United States and in a region that has enacted a relevant personal data protection law, you can find additional privacy disclosures that may apply to you at Non-US Privacy Disclosure.

Capitalized terms contained but not otherwise defined in this Notice have the meanings provided in our Terms of Service.

Scope

LXC is a service of the President and Fellows of Harvard College (“Harvard University”). This Notice applies to information that we collect in connection with our Services.

To become a Registered User of the Services you must first create a user account with LabXChange directly or with one of our third-party sign-on services like Google or Facebook.The information collected by a third party when you register on their site will be governed by that organization’s privacy policy and terms of use and is not under our direction or control. Some of the information collected when you create a user account with a third party site will be shared with LXC and will be subject to LXC’s Privacy Notice to the extent it is in our possession, but that third party’s privacy policy will continue to apply to the use and disclosure of your information by the third party.

This Notice does not apply to information that you may provide to Harvard University independently of our websites and Services.

Your use of the Services is subject to the LXC Terms of Service, which incorporate this Privacy Notice.

Nature, Use, and Disclosure of Information

Information we collect

We collect information, including Personally Identifiable Information, when you register for a User Account, access the LXC website, create a profile on the LXC website, or otherwise use the Services or communicate with LXC. “Personally Identifiable Information ” means your name, your email address, and other information that personally identifies you or that pertains to you as an identified or identifiable individual. We encourage you to use discretion before voluntarily sharing Personally Identifiable Information through the Services.

You can use many features of the Services without registering for an account. Information relating to your use is collected whether or not you have registered.

The following are examples of the information we collect:

When you register for an LXC User Account using a third party site, such as Google or Facebook, we collect certain pieces of your personal information from them. This includes your full name, email address, country or region of residence, and city. In addition we collect your date of birth from you. You may choose to provide additional Personally Identifiable Information when you create your LXC profile.
We also may obtain information about you when you contact our technical support team, send us email or receive email from us, participate in a user survey, or otherwise communicate with us through the Services.
When you use our Services, we may collect information about which Resources, Services, 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 also may collect a variety of other 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.
We may be able to determine your geographic location (or the location of your device or ISP) with such data. You may be able to change the settings on your computer or mobile device to prevent it from providing us with any location information.
We may also collect information about you, including Personally Identifiable Information, from third parties. This may include, for example:some text
- Information provided by your employer or an organization with which you are affiliated, such as when they authorize you to use the Services on their behalf.
- Information provided by other users, such as when an educator generates information about you using the LXC class functionality (a “Class”) or when a mentor generates information about you.
- Information provided by our partners and service providers. For example, from time to time, we may offer a special program or activity in partnership with a third party. If you participate in these special programs, we may collect information from you or from the partner to facilitate those programs.

We and third parties use web analytics and other automated tools to obtain some of the information we collect. These tools include cookies, pixel tags, scripts, log files, web beacons, and other similar technologies, which are further described at Cookies And Similar Technologies. Some of the cookies and tracking technologies on our Services are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies). For more information about data collected by third parties, please see “Use of certain third-party applications, websites and social networks” below.

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 our Services may not work properly or at all. We will attempt to honor your privacy preferences, but we may not be able to honor all of them, including, for example, Do Not Track signals sent by your browser.

How we use the information we collect, whom we share it with, and the reasons we share it

We use the information we collect to make our Services available to you. We may also use the information to communicate with you about the Services, and in the other ways described below.

We share the information as necessary to provide the Services, as well as for other purposes described below. For example, to provide the Services, we share some of your information with LXC staff, and other users of our Services, who can view your profile and username and, in some cases, the Resources you have contributed, as well as postings you make on forums provided by LXC. We also share information with a limited number of third-party contractors who perform certain functions on our behalf. For example, we share information with institutions and others who have contributed Resources and other content to our system, for purposes including enabling them to understand the use of their content and to improve its performance and value.

Comments or other information posted or contributed by you to any part of our Services designed to be visible to the public or to other LXC participants may be viewed by others who use or access the Services. Please bear this in mind when you post comments or other information.

We may collect, use, process, store, and share information about you, including in some cases Personally Identifiable Information, in the following ways:

To authenticate your identity.
To respond to a specific inquiry or provide you with access to the specific Service or Resource you select.
To provide, administer, maintain, improve, individualize, and evaluate the Services. This may include sharing information with LXC staff, administrators, and others who are involved in performing these functions for us, as well as with other third parties in some circumstances.
To provide or conduct the Services by sharing information about you (including Personally Identifiable Information) with other users of the Services. This may include, for example, sharing Resources, comments, and other content that you submit (“User Content”) with other users of the Services, along with your name, user name, photo, geographic location, and/or other potentially identifying information, and providing other users with other information that you have elected to share.
To perform research – for example, academic, scientific, or educational 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 us, Harvard University, or selected contributors and other partners, that may be of interest to you.
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, for example, analytics and information processing; processing emails, blogs, and other subscriptions; 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 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 Service or this Privacy Notice, illegal activities, fraud, security, or technical issues, misuse of the Services, or other misconduct, or to enforce our Terms of Service 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 share aggregated, anonymized information with the public and with third parties, including but not limited to researchers and partners.
If you are located outside of the United States, to serve you targeted advertisements on other websites, apps, or services, including on Facebook and other social networks, or on other devices you may use, using interest-based advertising and third party advertising companies.

If the Services that you use are subject to the Family Educational Rights and Privacy Act (20 U.S.C. 1232g) and the Family Educational Rights and Privacy Act Regulations (34 CFR Part 99) (together, “FERPA”), we may disclose information consistent with FERPA to the extent FERPA applies.
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.

Use for personalization and pedagogical improvements

We aim to provide current and future users of the Services with the best possible educational and learning experience. We may conduct research intended to enhance our offerings and the quality of learning and related sciences more generally. To further these goals, we sometimes present different users with different versions of our content. 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 content and services, to improve our understanding of the learning process, and otherwise to improve the effectiveness of our offerings, 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.

We may collect usage information about your use of our Service, such as the number of problems you have attempted, the number of videos you have viewed, and the amount of time spent to complete a problem. This enables us to better tailor educational experiences that are most appropriate for you.

We may use data that is no longer personally identifiable because it has been aggregated or anonymized for product development, research, analytics, and other purposes, including for the purpose of analyzing, improving, or marketing the Services. LXC may share this data with business partners and others for those purposes.

Disclosure to other users of the Services

The Services may make your information accessible to other Users, for example, other members of a Class you participate in or a person who agrees at your request to be your mentor on LXC (a “Mentor”). Once information about you is made available to others online, it may be collected and used by the recipients in ways we cannot control. For example, your personal information may be visible to others in the following circumstances:

Information you post to shared spaces of the Services. When you post content or participate in a discussion group on the Services your profile, which could include, among other things, your name and location information you provide, as well as the comment or other content you post, will be visible to other Users. Accordingly, please be careful about including Personally Identifiable Information in your posts.
Connecting with a Mentor. When your account is connected to a Mentor on the Services, the Mentor will be able to see your profile information and your activities on the Services, such as which videos you have watched, the questions and responses you post, and other usage information.

Use of certain third-party applications, websites and social networks

We may display content from, or provide links to, third-party sites and resources. Our Services display embedded content from, and contain links to, websites and other resources of third parties, including other content partners, survey tools, and service providers, which may capture Personally Identifiable Information as you use our Services. One example of such content is videos from YouTube that are displayed as part of the Services. Since we display YouTube videos, YouTube collects various kinds of information from you when you use our Services, as described in its privacy policy. YouTube and those other third parties may also serve you advertisements as part of their content or service. Those websites, applications, and resources are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by them or for their content. We encourage you to be aware when you are viewing third-party content via our Services or are redirected to a third-party website, application, or resource, and to review the privacy policies and terms of use of each website, application, and resource you visit or use.

We may share data with social networks at your request. If we permit you to connect your LXC user account with social networks or similar services, and if you decide to do so (which you may choose at your discretion), we may disclose your Personally Identifiable Information to the social network or other service.

We may share data with third-party applications that you authorize. Third-party application developers and service providers (commonly known as “App Developers”) may build services complementary to our Services, such as a mobile application that interacts with our platform, or may use our content to build unaffiliated applications and services if permitted. If you connect your LXC user account to a third-party application or service, or approve access to your LXC user account by a third party application or service, you consent to LXC sharing information collected from you or about you, including Personally Identifiable Information, with that third party.

We may share data in connection with special programs you participate in. If you participate in special programs where we partner with third parties, we may share data collected from or about you, including Personally Identifiable Information, with our third party partners to facilitate the program or services being offered. For instance, if you participate in a Class sponsored by your school, LXC may share information about your participation with your school and educator. These program partners may use your information we share with them as described in their own privacy policies.

We use Google Analytics, and may use other third-party analytics tools, to help us measure traffic and usage trends for our website and to understand more about the demographics of our users. Google Analytics uses cookies and similar technologies to collect and analyze information about the use of our website and report on activities and trends. That service also may collect information regarding your use of other websites, apps, and online resources. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

If you are located outside of the United States, we may participate in interest-based advertising and allow use of third-party tracking technologies on the Services for this purpose. We do not display any targeted advertising on our Services. However, we may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements on other websites, apps, and services, including on Facebook and other social networks, or on other devices you may use. These third-party ad networks use tracking technologies to recognize your browser or device and to collect information about your use of our Services in order to provide you customized content, advertising, and commercial messages that may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. You may be able to opt out of some interest-based advertising using resources such as those of the Network Advertising Initiative at www.networkadvertising.org/choices or the Digital Advertising Alliance at www.aboutads.info/choices.

Disclosure in the event of transfer of Services

In the event that the Services are transferred to another organization, information about you, including Personally Identifiable Information, may be transferred or disclosed to LXC’s successor and others involved in the transaction.

Security

The security of your Personally Identifiable Information is important to us and we endeavor to protect Personally Identifiable Information in our 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.

Processing Outside Home Country

LXC is operated and managed on servers based in the United States but it and its partners and service providers use third party service providers such as, for example, Amazon Web Services that may transfer information out of the United States in some situations. Thus, if you choose to use our Services from locations outside the United States, your use of the Services will require the transfer of information, including your Personally Identifiable Information, from your home country to the United States and possibly to other countries whose privacy laws may provide less protection than the laws in your home country. Such transfers are necessary for us to process your registration, if you wish to be a registered user, and to provide you the Services in accordance with our Terms of Service. If you do not wish to have such transfers occur you should not use our Services.

Collection of Data from Children

Our Services are not intended for users under the age of 13. We do not knowingly collect personal data from anyone under 13 years of age. If we become aware that a person under 13 years of age has registered we will, to the extent feasible, delete any Personally Identifiable Information of such person from our records.

School Users and Education Records

If you are a student at a school that has entered into an agreement with us to use our Services as part of the school’s educational curriculum, some of the information that we hold may be “Education Records” as that term is used in FERPA. Where we have such a contract with your school, information about your participation in a Class created or administered by your teacher or your school will be Education Records. This includes information such as the results of assessments in that Class or your posts on a discussion board that is specific to that Class. However, if you use our Services outside of a Class sponsored by your teacher or school, information collected by us related to those additional uses will not be Education Records. For example, information related to your connections to a Mentor, or a Class led by someone not affiliated with your school, will not be part of your Education Records.

We will use and disclose information from Education Records only as permitted by our contract with your school, this Privacy Notice, and applicable laws, including FERPA. Consistent with the foregoing, we may share information from your Education Records directly with your teacher or school.

If you have specific questions about reviewing, modifying, or deleting information from your Education Records, please contact your school directly.

Deletion of Your Account

To delete your account and remove information from the Service, log into your account and select “delete your account” through Settings. When you select “delete your account,” LXC will permanently deactivate your account and remove your profile and the personally identifiable information contained in your profile, subject to the limitations described below. We also will delete other information from our servers, including all posts and direct messages sent by you, though this process will not eliminate all information about you. For example:

Posts and direct messages written by others will not be deleted and may contain your name or other information about you.
Your information in activity logs and archives that we maintain will not be deleted until those logs or archives are deleted according to our normal business practices.
We will not remove content or information that we may need to comply with our legal obligations, resolve disputes, enforce our agreements, or as otherwise permitted or required by law.
Information about you that is not personally identifiable, because it has been aggregated or anonymized, will also remain.

Please also note that deletion of your LXC account will not automatically delete any third party account you might have used to register with LXC or the information it contains (i.e. Google, Facebook, edX, etc.). Regarding deletion of that information, please see that specific site’s privacy policy.

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.

If you are under the age of 18 and a California resident, you are entitled to request removal of content or information you have posted on our Service. You can request deletion of your entire account and remove all of your information on the Service using the procedures described under the heading “Deletion of Your Account” above. Please note that, as explained there, removal of your content or information does not ensure complete or comprehensive removal of all information relating to you.

Changing Our Privacy Notice

We may make changes to this Privacy Notice at any time. We 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. Changes made to our Privacy Notice 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.

Contact Us

If you have any questions or requests about this Privacy Notice or our handling of your information, you may contact us at privacy@labxchange.org.

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