Additional EEA Privacy Disclosures

Effective Date:  April 1, 2020

Last Updated:   April 1, 2020

The following European Economic Area (“EEA”) privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located the European Union, Iceland, Liechtenstein or Norway, which together comprise the 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.  In these Disclosures the words “we” or “our” refer to 

These Disclosures apply to EEA Processing Activities by any means, including 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, including the provision of your consent, 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.  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.  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.

What Personal Data Do We Collect?

We and our third-party vendors collect Personal Data through the website.  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; and
  • 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.

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 to facilitate transactions requested by you and meet our contractual obligations (for example, registering you for events); on the basis of our legitimate interests (for example, website analytics); or on the basis of your consent (for example, our newsletter), where applicable.

Engagement Opportunities

We collect and use various kinds of Personal Data, including about event participants, donors, and prospective donors, from a number of sources. This data includes that which you provide to us, for example, when you contact us, connect with us on social media, etc.  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 

What Personal Data 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;
  • Demographic Information:  for example, gender, age, and other information you may volunteer;
  • Personal Information and History:  for example, personal interests, charitable activities, other personal information you may choose to volunteer, and other information we may learn about your background;
  • Education History:  for example, prior and subsequent schools, awards, honors, and student activities;
  • Employment Information:  for example, your title, employer, location, and work experience;
  • Family Information:  for example, family member names, ages, occupations, and relevant medical information (if provided in advance of events);
  • Financial Information: for example, your contribution history, publicly available data on wealth and assets, and contributions to other organizations;
  • Payment Information:  for example, when you register for an event, make a donation or request a service, depending on your means of payment, your payment card number, or your bank and bank account number;
  • Contribution History:  your contribution history to us; and
  • Health and Dietary Information:  for example, medical conditions that may require additional accommodations or dietary preferences, if you volunteer such information.

What is the Purpose of Processing?

We process your Personal Data as part of our outreach and services:

  • To provide you opportunities to engage with us;
  • To facilitate donor communications, events, fundraising, and operations;
  • To request and process your contributions and subscriptions;
  • To communicate with you about other opportunities for giving, and to understand better your interests and how you might help support us through volunteerism and philanthropy;
  • To conduct analytics to improve our donor services, analyze engagement and contribution trends, and create custom experiences;
  • 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 on the basis of our legitimate interests (for example, requesting gifts or donations); to process transactions requested by you and meet our contractual obligations (for example, registration for events or processing of donations); as necessary for compliance with a legal obligation (for example, to provide required tax information); or on the basis of your consent, where applicable. 

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 to perform services on our behalf.  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 this data with us.

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 may be necessary to serve our legitimate interest in the following operations:

  • Conducting our operations;
  • Contacting you to respond to your requests or inquiries;
  • Providing you with newsletters, articles, announcements, event invitations, and other information that we believe may be of interest to you;
  • Requesting gifts and donations;
  • Alerting you about a safety or security announcement;
  • Conducting research, surveys, and similar inquiries to help us understand trends and needs of our users of our websites or other services;
  • 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:

  • Providing, improving, and customizing our offerings;
  • Administration of our operations;
  • Furthering research and understanding in relevant fields of study;
  • Maintaining an ongoing relationship with donors and prospective donors, and helping to connect them with others;
  • Requesting gifts or donations;
  • Offering attendance to events and opportunities to volunteer;
  • Understanding how our online platforms are being used;
  • Exploring ways to develop and grow our operations;
  • Ensuring the safety and security of our contributors and others;
  • Cybersecurity;
  • 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.  Additionally, we may share information as described below:

Service Providers

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;
  • Donor outreach and engagement;
  • Event registration and coordination;
  • Research insights and analytics;
  • Research collaboration;
  • Educational operations and collaborations;
  • 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: research arrangements with other universities or partners or  events and activities of 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

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 Data to legal or government regulatory authorities as required by applicable law.  We may 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

We may transfer your Personal Data internally 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. 

D.    Cookies and Similar Technologies

We may collect Personal Data about you, or information that becomes Personal Data if combined with other information, when you visit or use our website and online services.  This information may be collected through the use of cookies, which are small data files placed on your computer or mobile device that allow us to collect certain information whenever you visit or interact with our websites or online services.  Some of these cookies are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies).  This information may also be collected through the use of other data collection technologies (such as web beacons, pixels, or tags) that embed graphic files in our websites and online services.  These graphic files contain a unique identifier that enables us to recognize when someone has visited our website or online services, or in the case of web beacons, opened an email that we have sent them.

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; or
  • 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.

You can control the use of certain cookies and similar technologies by:

If you choose to reject certain cookies and similar technologies, you may still use our websites and online services though your access to some functionality and features may be restricted.  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.

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  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 require contacting us at 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 other 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.    Representative

At this time, we do not have a designated representative in the European Union for the purposes of GDPR. This is because our processing of EU-based data is occasional, does not include large scale processing, does not include special data categories (as described in GDPR Article 9(1)), and is unlikely to present risks to rights and freedoms of EU data subjects.

I.    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:
  • Address:  Armed Conflict and Civilian Protection Initiative
    Harvard Law School
    6 Everett Street, 3rd Floor
    Cambridge, MA 02138 USA