Skip to content HARVARD.EDU Menu Toggle extended navigation Additional Privacy Disclosures under Non-US Law for Individuals Located Outside the United States Last Updated: September 15, 2023 Introduction 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, “Personal Data” means information relating to an identified or identifiable individual; an identifiable individual is one who can be identified, directly or indirectly, by use of any identifier or characteristic specific to that individual. “Relevant Law” means any non-U.S. jurisdiction’s personal data protection law that applies to the processing of Personal Data by a Harvard Entity. “Relevant Country” means a country which has enacted a Relevant Law. “In-scope Processing” means the collection, use, handling, processing or sharing of Personal Data by a Harvard Entity when those activities are within the scope of any Relevant Law. “Harvard Entity” means a Harvard University school, center, or other Harvard unit or Harvard-controlled entity. 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 any such Harvard Entities. 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 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 use the Personal Data that we collect to carry on various institutional and educational activities 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. 1. Personal Data We Collect Websites and Mobile Applications 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. Read More What Personal Data Do We Collect? We and our third-party vendors collect Personal Data through websites and mobile applications, often as a result of users volunteering their data. We and our third-party vendors may collect: Contact Information: for example, your name, home address, email address, phone number and social media usernames; Log Files: Information collected automatically when you are interacting with websites or mobile applications, for example, IP address, browser type, internet service provider, pages visited (including referring/exit pages), operating system, date/time stamp and/or clickstream data; Cookies and Similar Technologies: Information collected automatically through cookies and similar technologies. For more information regarding our use of cookies and similar technologies, see the “Cookies and Similar Technologies” section below; Location Information: We may use your IP address to identify the general geographic area from which you are accessing our website. Our mobile applications may collect more precise location information about you to provide functions identified in the application, such as a map feature; and Mobile Device Sensor Information: Some of our mobile applications may use various sensors and components of your mobile device (for example, your camera or microphone) to collect information for the purposes of providing you with additional functions and features. What is the Purpose of Processing? We process your Personal Data collected on our websites and mobile applications: To facilitate our online interactions with you, for example, by responding to your requests; To operate, maintain and improve our websites and mobile applications, for example, by conducting analytics to improve and manage our websites and mobile applications, analyze user trends, and create custom audience lists; To collect data about you and your activities online over time and across different websites and social media channels for marketing purposes, including delivering relevant marketing communications to you; or To engage in other activities described under “Additional Uses of Personal Data” below. What is Our Legal Basis of Processing? 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: 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; or on the basis of your consent, where applicable. Admissions and Financial Aid We collect and use various kinds of Personal Data when you apply for admission to a Harvard School or to a program or course offered by us, and when you apply for financial aid, if available. The primary source of these data is your voluntary submissions. We may solicit additional data, for example, from interviewers as part of the admissions process, if applicable, or from other available sources when we are looking for potential candidates for admission in connection with recruiting activities. The Personal Data collected by us, or on our behalf, during the admissions process are used for the primary purposes of considering your candidacy for admission to the relevant School, program or course, evaluating your eligibility for financial aid, if applicable, and, if you are admitted and enroll, facilitating your education (such as by sharing Personal Data with registrars and others in order to enable your enrollment and participation in the School, program or course to which you have been admitted). Read More What Personal Data Do We Collect? We collect Personal Data as part of our admissions process and financial aid process. We also collect Personal Data in connection with registration for open enrollment programs. We and our third-party vendors (including, but not limited to, application and admissions/financial aid data base vendors such as the Common Application, the College Board, Technolutions, the Law School Admissions Council and the American Medical College Application Service) may collect: Contact Information: for example, your name, home address, email address and phone number; Demographic Information: for example, gender, age, and other information you may volunteer, such as in your application or essay; Education History: for example, your prior schools, transcripts, school activities and disciplinary records; Testing History: for example, standardized testing and corresponding identity verification documentation; Personal Information and History: for example, personal interests, extracurricular activities, recommendations, other personal information you may choose to volunteer, including in your application or your essay, and other information we may learn about your background; Health and Dietary Information: for example, immunization records, plus medical information or dietary preferences volunteered by you that may indicate a need for accommodations; Employment History: for example, job title, location and work experience; Personal Financial Information: for example, government identification number, personal and business tax reports, wage reports and statements, bank statements, socioeconomic status, scholarships and grants, and family support; Family Information: including family member names, ages, education information, occupations, wages and savings; Payment Information: depending on your means of payment, your payment card number or your bank and bank account number; and Log Files, Cookies, Location Information, and Mobile Device Sensor Information: When you use our websites or mobile applications, we also may collect additional information about you and your device as described in the “Websites and Mobile Applications” section above. What is the Purpose of Processing? We process your Personal Data as part of our admissions and financial aid processes: To consider your candidacy for admission and eligibility for financial aid; To respond to your requests and communicate admissions and financial aid decisions; To facilitate our operations relating to the admissions and financial aid process; To conduct research and analytics (for example, relating to application and admissions trends); To provide you with services related to the course or program, including assistance with travel, residential lodging and dietary or medical needs. To satisfy legal, regulatory and contractual obligations; or To engage in other activities described under “Additional Uses of Personal Data” below. What is Our Legal Basis of Processing? 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: to pursue our legitimate interests (for example, providing educational offerings and conducting admissions research); to process transactions requested by you and meet our contractual obligations (for example, to process your application for admission); as necessary for compliance with a legal obligation (for example, financial aid reporting); or on the basis of your consent, where applicable. How is My Personal Data Used if I Am Admitted? If you are admitted to a School or program or course offered by us, your Personal Data will be shared as necessary for registration and enrollment, including, as applicable, with the registrar of the school admitting you. Your Personal Data may also be shared as necessary to deliver and administer your education and related activities with other persons or entities, including Harvard departments, faculty and staff, financial aid sources, and governmental authorities. For example, your name and other contact information may be shared with a professor in whose course you enroll, in order to administer financial aid, with Harvard University Health Services to enable you to obtain treatment, or for other reasons consistent with our efforts to provide educational services to you. 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 sour…