Privacy Policy

Revised 3 June 2016

This Privacy Policy applies to information that HMX collects through the onlinelearning.hms.harvard.edu domains and other websites, applications, programs, and on-line or mobile products and services of HMX (collectively, the “Services,” and each a “Service”). By registering for, downloading, accessing or using any of the Services, you accept and agree to this Privacy Policy, whether or not you are a registered user or have an account.

If you do not agree to this Privacy Policy, do not register for, download, access or use any of the Services. This Privacy Policy does not apply to information that we may collect from you in other ways (for example, the 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 or Harvard Medical School independently of the Services). In addition, please note that your education records are protected by the Family Educational Rights and Privacy Act (“FERPA”) to the extent FERPA applies.

Remember that your use of the Services is at all times subject to the HMX Terms of Service, which incorporate this Privacy Policy.

As used in this Privacy Policy, “we,” “us” and “our” refer to HMX, which is a unit of Harvard Medical School.

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 HMX 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.

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 HMX Terms of Service or such other terms of use as may be provided for the applicable Service. You hereby consent to the collection, use, disclosure and retention by HMX of your Personally Identifiable Information (defined below) and other information as described under this Privacy Policy, including but not limited to the transfer of your Personally Identifiable Information or other information between HMX 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 choose not to provide us with certain information required to provide you with various programs offered on a Service, you may not be able to establish a user account and we may not be able to provide you with those programs.

As used in this Privacy Policy, “Personally Identifiable Information” means your full name and other information that personally identifies you.

We may collect information, including Personally Identifiable Information, when you sign up for a user account, download an application, participate in our online programs or communicate with us through the Services. We may also collect, use, store and share certain usage 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 HMX 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 forth in this policy.

Among other things, we may collect, use, process, store and share the information about you collected through a Service (including your Personally Identifiable Information) as follows:

• 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 HMX services and offerings, both individually and in the aggregate. This may include sharing information with HMX 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 an HMX 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 onlinelearning@hms.harvard.edu. For a description of information we define as Directory Information and for additional information regarding FERPA, see the FERPA Statement . 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 Partner Institution or Organization with which you are affiliated regarding your participation and/or performance in HMX programs.
• 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 HMX, the Harvard Medical 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 HMX, Harvard Medical School or Harvard University, or selected educational or business partners, that may be of interest to you.
• To enable HMX, Harvard Medical 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 HMX 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 Service or this Privacy Policy, illegal activities, fraud, security or technical issues, misuse of the Services, or other misconduct, or to enforce our Terms of Service 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 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).

We aim to provide current and future users of each Service with the best possible educational experience. We may conduct research intended to enhance HMX’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.

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 HMX. 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.

HMX 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.

We may make changes to this Privacy Policy at any time, but will alert you that we are doing so by giving notice on the Services or by some other means. By registering for, downloading, 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.

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.

If you have questions about this Privacy Policy or privacy concerns regarding the Services or HMX, please contact us at onlinelearning@hms.harvard.edu.