Frankly Privacy Statement

This privacy statement (“Privacy Statement”) explains the data privacy practices of the Frankly online discourse platform (the “Services”) offered by President and Fellows of Harvard College (“Harvard”, “we”, “us”), acting by and through the Applied Social Media Lab at the Berkman Klein Center for Internet and Society. This Privacy Statement applies only to the Services, and does not necessarily describe the data collection or processing practices of any other Harvard school or unit. We may update this Privacy Statement from time to time and will post any changes on this page. We encourage you to check our website frequently to review the most up-to-date version.  

PERSONAL INFORMATION WE COLLECT 

The personal information we collect may depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. 

1. Information You Provide to Us Directly 

We may collect the following personal information that you provide to us. 

• Community Creation. We may collect information when you create a community, including information about your company or organization. 

• User Account Creation and Configuration. We may collect information when you create a user account, including your name, email address, profile photo, social media handles, and password. 

• Event Registration Information. We may collect information that you provide when you schedule or join an event, such as your name, profile photo, and answers to registration questions. 

• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us. 

• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information. 

• User Content. We may collect personal information that you submit or make available through our interactive features, including posts and announcements in community spaces, audio and video from events, including recorded events, content shared via messaging and chat features, commenting functionalities, forums, or blogs, and responses to surveys and questionnaires from communities and event hosts (all such content, collectively, “User Content”). We may access your User Content as instructed or authorized by you, or as required for legal, safety, or security reasons. Any information you share in publicly visible portions of the Services, including any posts or announcements that you make in a community space, whether the community is labeled “public” or “private,” may be generally accessible to the public via the internet. Please exercise caution before revealing any information that may identify you in the real world to other users.  

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events. 

2. Information Collected Automatically 

We may collect personal information automatically when you use our Services: 

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during, and after using our Services, information about the links you click, the types of content you interact with and the communities that you join, the frequency and duration of your activities, and other information about how you use our Services. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you. 

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content or functionality to us or on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. Our uses of these Technologies fall into the following general categories: 

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications and tools that are required to identify irregular website behavior, detect fraudulent activity and improve security, or that allow you to make use of our functionality; 

• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below); 

• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed; 

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies. 

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here. 

• Social Media Platforms. Our Services may contain buttons from social media platforms such as Facebook and LinkedIn (including widgets such as the “share this” button or other interactive mini programs). If you interact with such features, these platforms may collect information such as your IP address or which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms, including via such buttons, are governed by the privacy policies of the companies providing them. 

3. Information Collected from Other Sources 

Other sources, such as third-party services and organizations which you use or are affiliated with, may share information about you with us. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, that third-party application may provide us with information about you. Your use of such third-party services and the services’ collection, use, and processing of your information, may be subject to additional terms, conditions, and policies between you and such services.  

HOW WE USE YOUR INFORMATION 

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.  

1. Provide Our Services 

We use your information to provide you with our Services, such as: 

• Managing your information and accounts; 

• Providing access to certain areas, functionalities, and features of our Services; 

• Answering requests for customer or technical support; 

• Communicating with you about your account, activities on our Services, and policy changes; 

• Allowing you to register for events.  

2. Administrative Purposes 

We may use your information for various administrative purposes, such as: 

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud detection; 

• Detecting security incidents, and protecting against malicious, deceptive, fraudulent or illegal activity; 

• Measuring interest and engagement in our Services; 

• Improving, upgrading, or enhancing our Services; 

• Developing new products and services; 

• Ensuring internal quality control; 

• Authenticating and verifying individual identities; 

• Debugging to identify and repair errors with our Services; 

• Auditing relating to interactions, transactions, and other compliance activities; 

• Enforcing our agreements, policies, and legal rights; and 

• Complying with our legal obligations. 

3. Promoting our Products and Services 

We may use personal information to tailor and provide you with content and recommendations. We may provide you with these materials as permitted by applicable law. 

Some of the ways we market to you may include email campaigns and recommendation of products, features, communities, or events offered on the Services, including targeted recommendations. 

If you have any questions about our marketing practices you may contact us as set forth in “Contact Us” below. 

4. Other Purposes 

We also use your information for other purposes as requested by you or as permitted by applicable law, including as described below. 

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. 

• De-identified or Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. 

HOW WE DISCLOSE YOUR INFORMATION 

We disclose your information to third parties for a variety of business purposes, including to provide our Services, or to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

1. Disclosures to Provide our Services 

The categories of third parties with whom we may share your information are described below. 

• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services, including via application programming interfaces or software development kits made available by such service providers. This includes service providers that provide us with certain features or functionality of the Services, as well as hosting, payment processing, customer service, and related services. 

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested.  

• Affiliates. We may share your personal information with our affiliated entities. 

• Other Users. As described above in “Personal Information We Collect,” your use of our Services requires us to share certain User Content, including but not limited to your profile information, with other users. For example, other participants in the same events or community spaces as you may see User Content such as your profile information, chat messages, and posts, while event hosts and community administrators may have access to additional information about your participation in their events and communities, including but not limited to your responses to registration questions, the time you spend in an event, breakout rooms you may join, suggestions that you submit, and chat content. 

2. Disclosures to Protect Us or Others 

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests or legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. 

3. Disclosure in the Event of Merger, Sale, or Other Asset Transfers 

If we are involved in a merger, acquisition, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. 

YOUR PRIVACY CHOICES  

The privacy choices you may have about your personal information are determined by applicable law. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you are using or have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Statement). 

SECURITY OF YOUR INFORMATION 

The Services have security measures in place to protect against the loss, misuse, and alteration of the information under our control. Unfortunately, due to the nature of internet communications, no data transmission over the internet can be guaranteed to be completely secure. While we remain committed to protecting the privacy of our users, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. To the fullest extent permitted by applicable law, we do not accept liability for any unauthorized disclosure. 

RETENTION OF PERSONAL INFORMATION 

We store the personal information we collect as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

CHILDREN’S INFORMATION 

The Services are not directed to children under 13 (or other age as required by applicable law), and we do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information in violation of applicable law, we will take steps to delete any such personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if any. 

OTHER PROVISIONS 

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. If you provide personal information to third-party websites or applications, you do so at your own risk. 

Users located outside the United States of America. If you are located in a country outside of the United States which has enacted a personal data protection law, please review additional privacy disclosures that may apply to you. 

Changes to our Privacy Statement. We may revise this Privacy Statement from time to time in our sole discretion. You understand and agree that you will be deemed to have accepted the updated Privacy Statement if you continue to use our Services after the new Privacy Statement takes effect. 

CONTACT US  

If you have any questions about our privacy practices or this Privacy Statement, please contact us at: 

Applied Social Media Lab
Berkman Klein Center at Harvard University
1557 Massachusetts Avenue
Cambridge, MA 02138