Privacy Policy

 

It is Harvard Partners, LLP’s policy to respect your privacy regarding any information we may collect while operating our website. Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose, and otherwise make use of personal information. We have outlined our privacy policy below.

Harvard Partners, LLP and the other entities listed below (collectively, “Harvard Partners”, “we”, “us”, or “our”), 75 Arlington Street, Suite 500, Boston, MA 02116, is providing this privacy policy (hereinafter the “Privacy Policy”) to explain our personal information practices with respect to our website, communications, notifications and related services (“Services”). This Privacy Policy applies only to the use and collection of data by us in the course of our Services.

By using our Services, you acknowledge the terms of this Privacy Policy and, if you provide us with information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person or household, such as a name, postal address, e-mail address, telephone number (hereinafter “Personal Information”), you acknowledge the collection, use, and disclosure of your Personal Information as described in this Privacy Policy, where and as permitted by applicable law. We encourage you to read this Privacy Policy before sharing information as it provides important information regarding your use of our Services, our data and privacy practices, and explains your rights.

If you do not agree with this policy, please do not provide us with any Personal Information and do not use the Services.

Harvard Partners reserves the right to change this Privacy Policy at any time by posting a new or updated Privacy Policy. We will use the reasonable means available to us to make you aware of any update to this Privacy Policy. However, we recommend that you review such Privacy Policy periodically for changes. We will endeavor to display clearly when the Privacy Policy was last amended on the website prior to the change becoming effective. By continuing to access our Services, you indicate your acceptance of the terms of this Privacy Policy, and consent to the collection, retention and use of your Personal Information consistent with this Privacy Policy, as amended from time to time, where and as permitted by law.

Personal Information We Collect

Information Provided By You Directly

We collect and have collected in the past 12 months Personal Information about you that you affirmatively provide to us, including your:

• Name;
• Address;
• Telephone number;
• Email address.
• Inferences drawn from personal information you provide us regarding topics of information you may be interested in.

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of the features our Services provide, including not being able to receive newsletters or marketing information. We may collect this information from you when you submit a form or request on our website, email us, call us, or otherwise contact us.

Job Applicants

If you apply for a job with us, we will collect and have collected in the past 12 months additional information in connection with your application. This may include:

• Name and contact information;
• Username and password;
• Work authorization status;
• Resume, CV, cover letter, work experience, and education information;
• Skills;
• Professional and work-related licenses, permits, and certifications held;
• Reference-related information; and
• Any other information that is publicly available or that you elect to provide to us (e.g., current salary, expected salary).

Such information may be collected from you directly, from your references, from a recruiter, from your prior employers, and from your places of education. We will only use this information to evaluate your candidacy, including by processing your application, assessing your qualifications, corresponding with you, and complying with legal obligations.

Information Collected Automatically

We also may collect and have collected in the past 12 months automatic information about how you use the Services online for, among other things, the operation and improvement of the Services. Such automatic information can entail collection and processing of: browser information, operating system information, unique device identifiers or your IP address, referring site, visit metrics, action metrics, page view metrics, search metrics, and others. This information may not be Personal Information.

This automatically collected information may be collected through technologies provided by third parties. Information that might be collected using these technologies includes, for example, the pages you visit on our online Services, the paths you take within our online Services, and the length of time that you spend on the Services. We use this information in the aggregate to better understand how to improve the quality of the Services.

We also collect and have collected in the past 12 months information about your activity, such as how you use our Services, how you interact with others using our Services, and the like, including information and confirmations regarding payments (payment receipts, including from app stores or other third parties processing your payment), device and connection information (when you install, access, or use our Services, hardware model, operating system information, browser information, IP address, mobile network information including phone number, and device identifiers), device location information if you use our location features, status information (online and status message changes on our Services).

As is common among Internet site operators, we maintain Web server logs. Web servers automatically identify your computer or mobile device by its IP address and collect that information in its Web server logs. An IP address is a number that is automatically assigned to your computer or mobile device by your Internet service provider or mobile service provider whenever you log onto the World Wide Web or access the Internet. The Harvard Partners’ Web server logs collect statistical data that is generated by your computer when it visits the Services, such as the type of Web browser and operating system used to access the Services, the domain name of your Internet service provider, the date and time you access the Services, and the pages you visit. Within the framework of the Services, we process this Web server log information for a variety of purposes. Some of these purposes include: system administration; examination of overall traffic trends on the Services; troubleshooting; and the collection of broad demographic information about users of the Services.

We may also collect and have collected in the past 12 months automatically your phone number if you call us.

Cookies

Like many websites, our online Services also use a technology called cookies or similar technology referred to as pixel tags (collectively, “cookies”). A cookie is a small text file that a Web server gives your browser to store on your computer when you access a website. Cookies can store many types of data and may be placed on your browser by Harvard Partners. We may also use cookies to store preferences; record session information; develop information about visitors’ preferences and interests; record past activity to provide better service when you return to the Services; or customize Web page content based on information you voluntarily provide.

In all cases in which cookies are used, however, Harvard Partners will not use the cookie to collect personally identifying information from the Services, unless you voluntarily agree to enter the information. Most Web browsers are set up to accept cookies. If you consented to our use of cookies but later wish to opt out, you can, however, reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our online Services may not work properly if you refuse cookies.

How We Use Your Personal Information

We will process your Personal Information to operate our Services. This may include the following uses:

First, we process Personal Information for the performance of a contract to which you are a party:

• To provide you with information or as otherwise disclosed to you when you provide us with your information, including, without limitation, receiving Harvard Partners announcements, information, and newsletters. In the event you are no longer willing to receive such information from us, you can opt-out at any time by following the instructions in the information you received or by notifying us at opt-out@harvardpartners.com. To verify your identity.
• To process job applications.
• To protect and defend the rights of Harvard Partners and its employees, our Services, or the users of the Services.

Second, we process Personal Information based on our legitimate interests:

• To contact you directly, when you provide us your contact information. If we contact you by email, you can opt-out of receiving future emails from us at any time by following the instructions in the email or notifying us at opt-out@harvardpartners.com.
• As incident to a sale, merger, reorganization, dissolution, bankruptcy, or similar event.
• Under circumstances we believe reasonably necessary to protect the personal safety of users of Harvard Partners’ products, our Services, or the public.
• To complete any transaction initiated by you with respect to our Services or to provide services or information to you.
• To better understand your needs, including by providing you with customized advertising, and how we can improve our products and Services accordingly. Please note that automated decision-making may be performed, including profiling, based on your Personal Information. However, such automated decision-making will not have any consequences, including legal effects, for you.

Third, we rely on your prior consent to:

• Store cookies for the purposes specified in the Section “Cookies.”
• As is otherwise described in this Privacy Policy or to the extent that you otherwise consent to such use in writing.

Please note that you have the right to withdraw your consent at any time by sending a request using the contact details in the Section “Contact Us.”

Finally, we process Personal Information to comply with the legal obligations to which we are subject, e.g., to detect and prevent fraudulent activities.

How We Share Your Personal Information

We do not sell and have not sold in the past 12 months your Personal Information. Personal Information may be shared, at times, with the following third parties: (i) our affiliates; (ii) third party service providers we hire to assist in the administration of the Services and/or the processing or handling of customer information (such service providers are required to maintain the confidentiality of user information and are prohibited from using it for any purpose other than as described in this Privacy Policy); (iii) competent authorities, as required by law, such as when compelled by subpoena or court order; (iv) third parties in charge of measuring the effectiveness of our programs and advertisements.

If Harvard Partners sells all or part of its business or the equity ownership thereof, makes a sale or transfer of all or a material part of its assets, or is otherwise involved in a merger, reverse merger, or transfer of all or a material part of its business, Harvard Partners may disclose and transfer your Personal Information to the party or parties involved in the transaction as part of that transaction. We will notify you and ask for your consent for such disclosure where required by applicable law.

The information you provide will be maintained for a commercially reasonable period of time by Harvard Partners for administrative, liability, and archival purposes, but in no event for longer than five (5) years after the termination of our contractual relationship.

We may also disclose the aggregate statistical data that we collect to third parties to allow them to measure the effectiveness of our programs and advertisements.

We may collect and store any “User Content” (as defined in our Terms and Conditions). We may retain and use User Content on our servers to improve performance and deliver media messages more efficiently, and to improve our Services. We may disseminate User Content to users, customers, and Services, including search engines, developers, and publishers, and organizations and firms that analyze the information for trends and insights.

Mobile Information

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Links

Our online Services may contain links to third party websites. Please recognize that we do not control these third-party websites, or how they may collect or use information that you may provide to them. Your use of third-party websites, along with the use of any information that such websites may collect from you, are not governed by this Privacy Policy. You should consult each applicable privacy policy before using another linked website.

Do Not Track

Because we may use the information that we collect through our online Services in the ways described in this Privacy Policy, we do not respond to “Do Not Track” requests or other similar mechanisms.

Security of Data Stored by Harvard Partners

Harvard Partners has implemented reasonable security measures to protect against the loss, misuse, and alteration of information under our control. While we make reasonable efforts to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third parties from illegally obtaining this information. If you have reason to believe that the security of your communications or Personal Information has been compromised, please immediately notify us at: privacy@harvardpartners.com

Collection of Personal Information from or About Children

We do not knowingly collect or process Personal Information from persons under age 13. If we learn that we have collected the personally identifying information of a user under the age of 13 without obtaining the prior consent of the holder of parental responsibility over him/her, we will take steps to delete the concerned information. If you are a parent and you think we have inadvertently collected and processed Personal Information from your child who is under 13 (or under the age of majority where you live), you may contact us by sending an email to privacy@Harvard Partner.com to request that we delete his or her information from our records.

Transfer of your Personal Information

Your Personal Information can be delivered to servers located in a different country than the one you are located in.

With respect to the entities or activities of Harvard Partners located in the European Economic Area, you authorize these entities to transfer, store, and use your Personal Information to the United States and other countries where we operate, where and as permitted by applicable law. Please note that, in some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live.

To ensure that, within the framework of the abovementioned transfers, an appropriate level of data protection is ensured regarding your Personal Information, Harvard Partners will only transfer Personal Information outside of the European Economic Area where appropriate safeguards to provide an adequate level of protection have been put in place.

By using our Services, you consent to the transfer of this personally identifying information and non-personally identifying information and to our use of such information as outlined in this Privacy Policy, where and as permitted by applicable law. If you are in a country embargoed by the United States, you will not engage in commercial activities using the Services. You will not use the Services if you are prohibited from receiving products, services, or software originating from the United States.

Retention of Your Personal Information

In accordance with our routine record keeping, we delete certain records that contain Personal Information you have submitted where they are no longer necessary for the purposes identified under this Privacy Policy. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information.

We will keep your Personal Information during the period of our contractual relationship, extended by the applicable limitation period.

As to the processing carried out to comply with a legal obligation, we will keep your Personal Information for the duration of such obligation.

On the expiry of the applicable data retention period, we will erase or irrevocably anonymize the relevant Personal Information.

Your Rights

If you have any questions about this Privacy Policy or any disclosure of Personal Information to third parties, please send an email containing your request to privacy@harvardpartners.com. You must provide your full name, and email address.

In addition, if you no longer wish to receive communications from us, you may opt out at any time by notifying us at opt-out@harvardpartners.com.

Rights for California Residents

The California Consumer Privacy Act of 2018, California Civil Code Sections 1798.100 et seq. (CCPA), may additionally afford rights to our users who are California residents. For example, California residents may have a right, following a verifiable request, to

(1) access—twice in a 12-month period, free of charge—for the 12-month period prior to the request, the categories and specific pieces of Personal Information Harvard Partners has collected about the user, the categories of sources from which the personal information is collected, the business purpose for collecting the personal information, and the categories of third parties with whom Harvard Partners shares personal information; and

(2) delete personal information under certain circumstances.

Such requests may be made by emailing us at privacy@harvardpartners.com. Harvard Partners does not discriminate against our users based on their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title.

Following any request, we will verify your identity using at least two data points you have previously provided to us. Please have this information available so that we can verify your request. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.

Rights for Users Within the European Economic Area

You have various rights in relation to and that depend on our reason for processing your Personal Information. In particular, you have the rights to:

• access to Personal Information processed concerning you;
• rectification of inaccurate Personal Information concerning you and a right to erasure;
• restriction of processing;
• erasure;
• data portability;
• object to the processing on grounds relating to your particular situation;
• withdraw consent previously provided (however, a withdrawal does not affect the lawfulness of processing of your Personal
• Information that occurred prior to the date of withdrawal); and,
• lodge a complaint with a supervisory authority, if you believe we have not complied with applicable data protection laws.

To exercise any of your rights, please contact us by email at privacy@harvardpartners.com. Harvard Partners will respond to your request in a reasonable timeframe, and in any event within one month from receipt thereof.

This Privacy Policy relates to the following entities:

• Harvard Partners, LLP

 

Contact Us

If you have any questions regarding our Privacy Policy, or need to access the policy in an alternative format due to a disability, please contact us at privacy@harvardpartners.com.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. Harvard Partners, LLP may change this privacy policy from time to time at Harvard Partners, LLP’s sole discretion.