EEA Privacy Disclosures
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Additional EEA Privacy Disclosures
Effective Date: May 25, 2018
Last Updated: May 30, 2018
The following EEA privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union, Iceland, Liechtenstein or Norway (the “European Economic Area” or “EEA”).
In these Disclosures,
- “GDPR” means the European Union’s General Data Protection Regulation;
- “Personal Data” means information that relates to an individual who is directly or indirectly identified or identifiable; and
- “EEA Processing Activities” means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.
These Disclosures apply only to the use of Personal Data in EEA Processing Activities. Further, these Disclosures apply only to the Harvard University Schools, Centers, and other Harvard units and controlled entities (collectively, “Harvard Entities”) that link to these Disclosures or expressly adopt them in writing. In these Disclosures the words “we” or “our” refer to each such Harvard Entity. In some cases a Harvard Entity may provide other information about its EEA Processing Activities in its own supplemental or separate disclosures.
These Disclosures apply to EEA Processing Activities by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).
A. How We Collect and Use Personal Data
We collect several categories of Personal Data in circumstances that may involve EEA Processing Activities, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sources.
We use the Personal Data that we collect to carry on various institutional and educational activities. As described in more detail below, we rely on a number of legal bases to lawfully process your Personal Data.
The ways in which we collect and use your data vary depending on the relationship between you and us, as well as the Harvard Entity with which you interact. The following sections of these Disclosures describe in more detail how we collect and use Personal Data in various circumstances that may involve EEA Processing Activities. Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR.
1. Personal Data We Obtain from You
Websites and Mobile Applications
As is true of most digital platforms, we gather 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 the data into form fields on a feedback page. If we also process data through our websites or mobile applications for one of the activities described further below, those sections will provide additional information about how data are collected and used. We and our third-party vendors collect Personal Data for the primary purposes of conducting analytics, responding to your requests and providing you with relevant information. Read more >
Alumni and Donors
We collect and use various kinds of Personal Data about alumni, donors and prospective donors from a number of sources, including data you provide to us, for example, when you update your alumni or donor profile, connect with us on social media, complete a donation form or register to attend Harvard events. If you were a student or studied at Harvard University, some of your Personal Data are transferred from your student record into our alumni databases. We may also collect Personal Data from publicly available sources or third-party sources that support our operations. The Personal Data collected by us, or on our behalf, is collected for the primary purpose of providing you opportunities to engage with Harvard, alumni, donors, prospective donors and students through interactions, events and your gifts or donations. We may disclose your data to other Harvard affiliated entities and individuals such as alumni clubs and special interest groups (SIGS) or volunteers when their work meets one of the purposes described below. Read more >
Employees and Job Applicants
We collect your Personal Data when you apply to work for us. Further Personal Data collection occurs at hiring and throughout your relationship with us.
The Personal Data collected by us, or on our behalf, are collected for the primary purpose of providing employment or enabling authorized persons to utilize our services and facilities. Read more >
2. Personal Data We Obtain from Third Party Sources
As part of our EEA Processing Activities, 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.
Partners and Service Providers
We use partners and service providers, such as payment processors (for example, CyberSource). 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 services or research activities may allow you to register and login to those services through a third-party platform. When you login to our service 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.
Supplemental Personal Data
We may receive additional Personal Data from third-party sources, such as public or private databases (for example, compilations of email or postal addresses), or companies or institutions that may sponsor or facilitate your participation in one of our programs, which we may also append to existing Personal Data.
3. Additional Uses of 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, may be necessary to fulfill our contractual commitments to you, may be necessary for legal compliance, or are necessary to serve our legitimate interest in the following operations:
- Contacting you to respond to your requests or inquiries;
- Providing you with newsletters, articles, service alerts or announcements, event invitations, and other information that we believe may be of interest to you;
- Requesting gifts and donations;
- At your request, processing and fulfilling transactions for merchandise or other Harvard products;
- Alerting you about a safety or security announcement;
- Conducting research, surveys and similar inquiries to help us understand trends and needs of our alumni and others using our websites or other services;
- Meeting the requirements of our accreditors;
- Performing 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;
- Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
- Responding to subpoenas, court orders, or other legal process; enforcing our agreements; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.
4. Legitimate Interests
We rely on several legitimate interests in using and sharing your Personal Data. These interests include:
- Administration of our operations;
- Maintaining an ongoing relationship with alumni, donors and prospective donors, and helping to connect them with others;
- Requesting gifts or donations;
- Offering attendance to events;
- Understanding how our online platforms are being used;
- Exploring ways to develop and grow our operations;
- Ensuring the safety and security of our alumni, employees, and others;
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
- Meeting our obligations and enforcing our legal rights.
5. Data Retention
We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures unless a longer period is required under applicable law, or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.
Where we are processing Personal Data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (see “Your Rights” below).
Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Where we are processing Personal Data based on the public interest, we generally retain the information for the period of time that continues to serve that underlying interest.
B. How We Share and Disclose Personal Data
We share your Personal Data with third parties in the ways described in these Disclosures. We may share your Personal Data with third parties as described in 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:
- Payment and contribution processing;
- Customer relationship management (CRM) services;
- Marketing and analytics;
- Alumni and donor outreach and engagement;
- Event registration and coordination;
- Enrollment verification;
- Research insights and analytics;
- Research collaboration;
- Performing human resources administration; and
- System maintenance and security.
We may share your Personal Data with other institutions for the purposes of administering programs and services, such as:
- Events and activities of Harvard-affiliated clubs and special interest groups.
Third-Party Mobile App Providers
With your knowledge and consent, our services on your mobile device may gather and transfer your Personal Data, including location information, from and to other applications, functions and tools within your mobile device if you use our mobile applications.
Social Media Platforms
Legal Process, Safety and Terms Enforcement
We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law. We also disclose your Personal Data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its 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.
C. International Data Transfers
Harvard may transfer your Personal Data between Harvard Entities and/or to the third parties discussed above. We may transfer your Personal Data outside the EEA relying on appropriate or suitable safeguards or specific derogations recognized under data protection laws, including the GDPR.
The European Commission has adopted standard data protection clauses, which provide safeguards for Personal Data transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal Data from a country in the EEA to a country outside the EEA. If your Personal Data are affected, you can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.
D. Cookies and Similar Technologies
These small data files or graphic files serve various functions:
- Strictly Necessary: Necessary to deliver our services;
- Performance and Functionality: Enhance the performance and functionality of our services but are non-essential to their use;
- Analytics and Customization: Allow us to understand the effectiveness of our services and marketing campaigns, as well as to customize our services based on this information; or
- Advertising: Make advertising messages more relevant to you and your interests.
You can control the use of certain cookies and similar technologies by:
- Opting out of targeted online advertising through advertising networks (please visit http://www.aboutads.info/choices/, http://optout.networkadvertising.org/?c=1#!/ or http://www.youronlinechoices.com for more information);
E. Your Rights
We will provide you upon your reasonable, good faith request with information about whether we hold any of your Personal Data as part of our EEA Processing Activities, to the extent required by and in accordance with applicable law. In certain cases, you may also have a right, with respect to your Personal Data collected and used in the EEA Processing Activities, to:
- correct or update any of your Personal Data that is inaccurate;
- to restrict or limit the ways in which we use your Personal Data;
- to object to the processing of your Personal Data;
- to request the deletion of your Personal Data; and
- to obtain a copy of your Personal Data in an easily accessible format.
To submit a request, please send an email message to [email protected]. Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we will ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.
You also have the right to withdraw your consent to our processing of your Personal Data as part of the EEA Processing Activities, where our processing is solely based on your consent, subject to certain limitations at law. In some cases, you can do this by discontinuing use of the services involved in the EEA Processing Activities. This would include by closing all of your online accounts with us and contacting us at [email protected] to request that your Personal Data be deleted. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures or the other Harvard privacy statements that link to or expressly adopt these Disclosures, you may not have access to all (or any) of the related services, and we might not be able to provide you all (or any) of the services. Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent and requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure.
If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority).
F. User Generated Content
Some of our services involved in EEA Processing Activities may enable users to submit their own content. Unless otherwise indicated, please remember that any Personal Data you submit or post as user-generated content could become public information. 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.
G. Updates to the Disclosures
We may update these Disclosures from time to time without prior notice by posting revised Disclosures to this site. You can determine when these Disclosures were last revised by checking the Last Updated date in these Disclosures.
H. Contact Us
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:
- Email: [email protected]
- Address: Harvard University
Attention: GDPR Coordinator
1033 Massachusetts Avenue
Cambridge, MA 02138 USA