Harvard Center Shanghai Personal Information Privacy Disclosures

Last Updated: February 11, 2022

Introduction

These privacy disclosures (these “Disclosures”) provide information about collection and use of data about individuals located in mainland China by or on behalf of Harvard Center (Shanghai) Co. Ltd. (“HCS”).

In these Disclosures,

  • Personal Information” means any information, recorded in electronic form or otherwise, which can be used, solely or together with other information, to identify a natural person located within the territory of the People’s Republic of China (“China”), including but not limited to name, date of birth, ID card number, and personal biometric information ; an identifiable individual is a natural person who can be identified, directly or indirectly, by use of any identifier or factor specific to that individual.
  • “PIPL” the Personal Information Protection Law, adopted August 20, 2021 by the Standing Committee of the National People’s Congress of China, and any implementing regulations or rules as may be adopted from time to time.
  • "In-scope Processing" means that collection, use, handling, processing or sharing of Personal Information by or on behalf of HCS when those activities are within the scope of PIPL. 

These Disclosures apply only to the use of Personal Information in In-scope Processing. Further, these Disclosures apply only to HCS. In these Disclosures, the words “we,” “us” or “our” refer to HCS.

These Disclosures apply to In-scope Processing by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).

  1. How We Collect and Use Personal Information

We use the Personal Information that we collect to carry on various HCS 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 Information in various circumstances that may involve In-scope Processing.

Please note that, depending on the situation, some of the processing of Personal Information we do that is described below may in fact not be In-scope Processing.

  1. Personal Information We Collect

Program Admissions

We collect and use various kinds of Personal Information when you apply for admission to a program taking place at, coordinated by, or offered through us. The primary source of these data is your voluntary submissions. We may solicit additional data, from other available sources when we are looking for potential candidates for admission in connection with recruiting activities. The Personal Information collected by us, or on our behlaf, during the admissions process are used for the primary purposes of considering your candidacy for admission to the relevant program and, if you are admitted and enroll, facilitating your participation (such as by sharing Personal Information in order to enable your enrollment and participation in the program to which you have been admitted).

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What Personal Information Do We Collect?

We collect Personal Information as part of our admissions process. We also collect Personal Information in connection with registration for open enrollment programs. We may collect:

  • Contact Information: for example, your name, home address, email address, phone number, social media usernames, and emergency contact information;
  • Demographic Information: for example, photographs (including photo ID), gender, age, date of birth, country of citizenship, and other information you may volunteer, such as in your application;
  • Education History: for example, your prior schools;
  • Personal Information and History: for example, personal interests, extracurricular activities, recommendations, other personal information you may choose to volunteer, including in your application, and other information we may learn about your background;
  • Health and Dietary Information: for example, immunization records, plus medcial information or dietary preferences volunteered by you; 
  • Employment History: for example, job title, location, work experience, professional and occupational qualifications, language capability, work experience (including names of former employers, positions, period of employment;
  • Payment Information: depending on your means of payment, your payment card number or your bank and bank account number; and
  • Your Image: for example, where you voluntarily provide a photograph or other image.

 

What is the Purpose of Processing?

We process your Personal Information as part of our admissions:

  • To consider your candidacy for admission;
  • To respond to your requests and communicate admissions;
  • To facilitate our operations relating to the admissions;
  • To conduct research and analytics (for example, relating to application and admissions trends);
  • To provide you with services related to the 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 Information” below.

How is My Personal Information Used if I Am Admitted?

If you are admitted to a program taking place at, coordinated by, or offered through us, your Personal Information will be shared as necessary for registration and enrollment. Your Personal Information may also be shared as necessary to deliver and administer your program and related activities with other persons or entities, including HCS affiliates and governmental authorities. For example, your name and other contact information may be shared with an instructor who is teaching in a program in which you enroll, or for other reasons consistent with our efforts to provide programming to you.

Programs and Activities

We collect your Personal Information when you apply or register for online or in-person program offerings. We and our third-party vendors also collect Personal Information when you participate in online or in-person programs and activities. In some cases, our collection of Personal Information from you in connection with online activities takes place as part of a “hybrid” program in which you also may participate in person, or as part of remote learning occurring in a program that is ordinarily conducted in person.

The Personal Information collected by us, or on our behalf, are used for the primary purposes of providing you with programming.

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What Personal Information Do We Collect?

We and our third-party vendors may collect:

  • Contact Information: for example, your name, home address, email address, phone number, and social media usernames;
  • Payment Information: depending on your means of payment, your payment card number or your bank and bank account number, and government identification number where legally required; 
  • Demographic Information:for example, gender, age, photographs (including photo ID), country of citizenship, and date of birth;
  • Personal Information and History: for example, personal interests, other information about yourself that you volunteer in profiles or otherwise on the online platform, and other information we may learn about your background;
  • Education Information: for example, schools, transcripts, awards and honors;
  • Employment Information: for example, your title and employer, history and work experience, professional and occupational qualifications, language capability, names of former employers, positions, and periods of employment;
  • Health and Dietary Information: for example, medical information or dietary preferences volunteered by you that may indicate a need for accommodations; 
  • Learner Interaction and Participation Data: for example, exchanges with other learners, forum contributions, community posts, and your participation in program sessions or other online events that are transmitted or recorded in audio and/or visual form;
  • Program Engagement and Assessment Data: for example, assignment responses and program interactions (such as the ways in which you move through and interact with the program materials); 
  • Log Files: 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 when you are interacting with our online program offerings. For more information regarding our use of cookies and similar technologies, see the “Cookies and Similar Technologies” section;
  • Location Information: for example, latitude, longitude, date and time (the precision of these data varies greatly and is determined by factors controlled by your device or mobile service provider); and
  • Your Image: for example, where you voluntarily provide a photograph or other image for use in an online program (for example, in a profile), or where you appear in a video transmission or recording.

What is the Purpose of Processing?

We process your Personal Information for online programs:

  • To provide and administer the program or activity in which you are participating, including evaluating your success in and engagement with the online offering;
  • To respond to your requests and communicate with you regarding current or future programs or activities;
  • To provide you with services related to the program or activity, including assistance with travel, residential lodging and dietary or medical needs;
  • To conduct research (for example, in the areas of education and cognitive science) and analytics related to our online offerings;
  • To satisfy legal, regulatory and contractual obligations; or
  • To engage in other activities described under “Additional Uses of Personal Information” below.

Employees, Interns, Job Applicants and Service Providers

We collect your Personal Information when you apply to work for us. Further Personal Information collection occurs at hiring and throughout your relationship with us. We may also collect Personal Information about personnel of vendors providing services to us.

The Personal Information collected by us, or on our behalf, are used for the primary purposes of providing employment, engaging with service providers, legal compliance, and enabling employees and service providers to utilize our services and facilities.

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What Personal Information Do We Collect?

We and our third-party vendors may collect:

  • Contact Information:for example, your name, home address, email address, phone number, travel calendar, and emergency contact information; 
  • Payment Information: your bank and bank account number for processing your compensation;
  • Tax Information: for example, government identification number, wages and filing status;
  • Personal Information and History: for example, marital status and other information about your background, and when relevant for your position or required by law, credit history, driving record, self-reported and publicly available criminal records, citizenship and work authorization status, national insurance numbers and housing and social insurance information;
  • Employment and Work History: for example, prior employers, titles, wages, work experience, reasons for departure, and disciplinary record, professional and occupational qualifications, language capability, labor handbook document number, referrals from former employers, work archives and records;
  • Education Information: for example, schools, transcripts, awards, honors and disciplinary records;
  • Family Information: names, work information;
  • Demographic Information: for example, gender, age and date of birth, passport/ID number, photographs (including photo ID), household registration, height, weight, blood type, and health condition;
  • Health Information: for example, physical check-up records for recruitment and during employment, doctor certifications for sick leave or medical treatment applications during employment, and medical information volunteered by you that may indicate a need for accommodations;
  • Your Image: for example, photo identification; and
  • Log Files, Cookies, Location Information: When you use our websites, we also may collect additional information about you and your device as described in the “Websites” section above.

What is the Purpose of Processing?

We process your Personal Information for employment or other work relationship and job application purposes:

  • To evaluate your application for employment or other work relationship and communicate hiring decisions;
  • To engage with service providers;
  • To administer and facilitate workforce-related processes and operations, including compensation processing and the provision of employee benefits;
  • To provide you with support services, including assistance with travel and dietary or medical needs;
  • To satisfy legal, regulatory and contractual obligations; or
  • To engage in other activities described under “Additional Uses of Personal Information” below.

Research

Our researchers, research collaborators and service providers may collect, use and share your Personal Information as part of a research study in which you have agreed to participate as a research subject, or in which your existing data are used. Most often, before any Personal Information is collected for research purposes, as a research subject you will be provided a consent and/or authorization form relating to the specific research project that explains the types of data collected and the purposes for which such data will be processed and shared. In such a case, the description of the collection and use of your Personal Information provided in the consent and/or authorization form will replace the information provided here. The Personal Information collected by our researchers, research collaborators and service providers, or on their behalf, are used for the primary purposes of furthering the particular research project and more generally for supporting research and understanding in fields of academic study.

Examples of Personal Information that may be collected for research purposes are listed below. Of course, a single research study will rarely collect all of these types of data. If you have questions about the processing of your data in connection with a research study, you should contact the HCS personnel who are conducting the research or the contact persons named in any consent form you signed when you joined the study.

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What Personal Information Do We Collect?

Examples of Personal Information that we and our third-party collaborators or service providers may collect for research purposes include the following. Please note that in most cases these data, if identifiable, would initially be provided voluntarily by you:

  • Contact Information: for example, your name, home address, email address and phone number; 
  • Payment Information: your bank and bank account number, and government identification number where legally required, for processing compensation if you are being paid in connection with the research;
  • Demographic Information: for example, race, ethnicity, gender, age, education, profession, occupation, income level and marital status, photo or other image (including photo ID);
  • Personal Information and History: for example, personal interests, profession, and other information about your background;
  • Family Information: for example, family members, ages, occupations and health;
  • Employment History: for example, employers, titles, wages, work experience, trade union membership and disciplinary record;
  • Education History: for example, schools, transcripts, awards, honors and disciplinary records;
  • Health and Dietary Information: for example, doctor’s records, surgical records, immunizations and medications, allergies and dietary preferences;
  • Biometric Data: for example, facial measurements, fingerprints and retinal scans;
  • Genetic Data: for example, genetic information obtained from your biological samples;
  • Course Engagement and Assessment Data: for example, assignment responses, test scores and course interactions (including, for example, the ways in which you move through and interact with the course materials);
  • Log Files: 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; and
  • Location Information: for example, latitude, longitude, date and time (the precision of these data varies greatly and is determined by factors controlled by your device or mobile service provider); and
  • Mobile Device Sensor Information: for example, health-related information that may be available through an application using a sensor or component of your mobile device.

If you are a researcher, research collaborator or service provider, we may collect your contact, payment, employment and education information to administer the study, manage our relationship and compensate you for your work.

What is the Purpose of Processing?

We may process your Personal Information for research in accordance with the purposes of the particular research projects, and also:

  • To further research and understanding in fields of academic study;
  • To enroll you in a particular research study as a research subject;
  • To administer the study;
  • To make reports to project funders and other project participants;
  • To satisfy legal compliance requirements; or
  • To make required reports to tax authorities on payments to research subjects, researchers and service providers.
  1. Personal Information We Obtain from Third Party Sources

As part of our In-scope Processing, we may obtain certain Personal Information 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 Information” above and in “Additional Uses of Personal Information” 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, analytics providers, and platform providers to provide services for us. Some of these partners have access to Personal Information 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.

Third-Party Platform Sign-On

Some of our program offerings may allow you to register and login through a third-party platform. When you login to our offering or activity through a third-party platform, you allow us to access and collect any Personal Information from your third-party platform account permitted under the settings and privacy statement of that platform.

Supplemental Personal Information

  1. may receive Personal Information from third-party sources, such as public or private databases (for example, compilations of email or postal addresses) and publications (for example, news reports), or companies or institutions that may sponsor or facilitate your participation in one of our programs, which we may also add to existing Personal Information.
  1. Additional Uses of Personal Information

In addition to the uses described above, including under “How We Collect and Use Information” and “Personal Information We Obtain from Third Party Sources,” we may use your Personal Information for the following purposes. These additional uses may under certain circumstances be based on your consent or may be necessary to fulfill our contractual commitments to you, for legal compliance, or to serve our legitimate interest in the following activities.

  • Conducting our operations and administering and developing our offerings;
  • Processing and responding to your requests or inquiries;
  • Providing you with newsletters, articles, service alerts or announcements, event invitations, volunteer opportunities, and other information that we believe may be of interest to you;
  • At your request, processing and fulfilling transactions for merchandise or other HCS products;
  • Providing travel-related services to you at your request;
  • Alerting you about a safety or security announcement;
  • Conducting research, surveys and similar inquiries to help us understand trends and needs of our applicants, program participants and others;
  • 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 will be of interest to you;
  • Ensuring the rights, safety and security of our employees and others;
  • 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 Information, our website or data systems; or
  • Responding to subpoenas, court orders, or other legal process; fulfilling and enforcing our agreements and legal rights; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.
  1. Consent for Processing

By using our website, applying to our programs, participating in our programs or otherwise interacting with HCS, you are voluntarily and explicitly granting HCS consent to process your Personal Information for the purposes described in these Disclosures.

  1. Data Retention

We will retain your Personal Information for as long as is necessary for the purposes set out in these Disclosures and for as long as is legally required, in accordance with PIPL.

We may also retain Personal Information as needed to resolve disputes or protect our legal rights.

Consistent with the foregoing guidance, some data may be retained indefinitely to the extent permitted under applicable law.

  1. How We Share and Disclose Personal Information

We share your Personal Information with third parties in the ways described in these Disclosures, including the “How We Collect and Use Personal Information” section above, as well as between HCS and other entities for which HCS provides services. Additionally, we may share information as described below:

Service Providers

We share your Personal Information 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 services;
  • Marketing and analytics;
  • Processing applications;
  • Event registration and coordination;
  • Providing program platforms or tools that enable or enhance our offerings;
  • Program registration and administration;
  • Program evaluations and assessments;
  • Enrollment verification;
  • Research insights and analytics;
  • Program operations and collaborations;
  • Performing workforce administration and operations;
  • System maintenance and security;
  • Facilitating other transactions with you; and
  • Assisting with our legal compliance.

Partners

We may share your Personal Information with other entities for the purposes of delivering programs and services, such as:

  • Cross-registration for program and events with other entities;
  • Program registration and administration;
  • Program evaluations and assessments;
  • Online program offerings through online platforms;
  • Events and activities of HCS-affiliated groups.

Social Media Platforms

We may also use services provided by third parties (such as social media platforms) to serve targeted ads or sponsored content on third-party platforms. For more information regarding our use of cookies and similar technologies, see the “Cookies and Similar Technologies” section below.

Legal Process, Safety and Terms Enforcement

We may disclose your Personal Information to legal or government regulatory authorities as required by law. We may also disclose your Personal Information to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine that 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.

  1. International Data Transfers

Much of our Personal Information processing takes place in China, though sometimes we or third parties with whom we share data may process data in other countries. In the event we transfer your Personal Information outside of China as part of our In-scope Processing, we take appropriate and suitable safeguards to maintain the confidentiality and security of your Personal Information as required under applicable law.

  1. Cookies and Similar Technologies

Whenever you visit or use our webistes or online services, we may deploy cookies and related technologies ("Cookies") to collect certain personal information about you. We use the information in order to enhance and personalize the experience, to help provide our services, to analyze website and service usage, and to help improve the websites and our related services. To find out more about cookies, visit https://www.internetcookies.org/. 

Third parties may also use Cookies embedded in our sites to collect information about your online activities over time and across different websites you visit. This information may be used by third parties to provide advertising tailored to your interests on other websites, apps and services you visit.

You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies, or you can opt out of the collection and use of some Cookies through tools like the Network Advertising Initiative opt-out page. If you disable or delete certain Cookies in your settings, you may not be able to use features of our websites.

We may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects information using Google Analytics, please see www.google.com/policies/privacy/partners/, and for how to opt out, please see https://tools.google.com/dlpage/gaoptout.

The opt-outs described above may not work for all browsers or devices.

If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.

  1. Your Rights

To the extent required by PIPL, upon your reasonable and good faith request, we will inform you whether we hold any of your Personal Information as part of our In-scope Processing. With respect to your Personal Information collected and used in our In-scope Processing, you may under PIPL also be able to:

  • access and obtain a copy of Personal Information about you, as well as information relating to our processing of that data;
  • request that we correct or update any of your Personal Information that is inaccurate;
  • request that we restrict or limit the ways in which we use your Personal Information;
  • object to the processing of your Personal Information;
  • request the deletion of your Personal Information;
  • request that we transmit your Personal Information to another party.

To submit a request, please send an email message to shanghaicenter_datasubjectrequest@harvard.edu. Because we want to avoid taking action regarding your Personal Information at the direction of someone other than you, we may need to ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.

If our In-scope Processing as to your Personal Information is based on your consent, in certain cases you may also have the right under PIPL to withdraw your consent to our processing. If you withdraw your consent to the use or sharing of your Personal Information for the purposes set out in these Disclosures, or otherwise limit our use of your Personal Information or request its deletion, we may no longer be able to provide you some or all of the related services.

Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent or requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may need to retain certain data to comply with an independent legal obligation, for achieving the lawful purposes for which we obtained the data, or for such reasons as keeping our services and operations safe and secure or safeguarding our rights or the rights or safety of others.

If you have any complaints regarding our privacy practices, you may be able to make a complaint to government authorities.

  1. User Generated Content

Some of our online activities enable users to submit their own content. Please remember that any Personal Information you submit or post as user-generated content in these circumstances could in some cases be seen by others or become public. 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.

  1. Updates to the Disclosures
  1. may update these Disclosures from time to time without prior notice by posting revised Disclosures. You can determine when these Disclosures were last revised by checking the Last Updated date at the beginning of these Disclosures.
  1. 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:

  • Name: Harvard Center (Shanghai) Co. Ltd.
    名称: 哈佛中心(上海)有限公司
    Address: Suite 505, HSBC Building 5th Fl., Shanghai ifc, 8 Century Avenue, Pudong New Area, Shanghai 200120, P.R. China

地址: 中国(上海)自由贸易试验区世纪大道8号上海国金中心汇丰银行大楼5505单元

Email: shanghaicenter_datasubjectrequest@harvard.edu