Revised 3 June 2016
Usernames and Contributions
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.
Consent to Processing Outside Home 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.
Personally Identifiable Information
Information We Collect and How We Use It
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.
Use and Disclosure to Third Parties
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 firstname.lastname@example.org. 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 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 share aggregated, anonymized information with the public and with third parties, including but not limited to researchers and business partners.
- 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).
Use for Personalization and Pedagogical Improvements
Links to Other Applications and Websites
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.
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.
Questions or Privacy Concerns