Last Modified: March 25, 2020
- Collection of Information
- Information You Provide
- Information Automatically Collected
We may use a variety of technologies such as cookies, pixel tags, web beacons, web server logs, and other similar technologies to collect certain non-personal information about your use of the LMS and interactions with our emails, and to allow us to keep track of analytics and certain statistical information.
For example, we may automatically collect information from your computer or other device used to access the LMS, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We may also collect information about your use of the LMS, such as the date and time of your visit, the information you searched to find the LMS, your participation in Program courses (such as recorded class sessions, assignments you submit, your communications on the LMS, surveys and other course data submitted by you), the areas or pages of the LMS that you visit; the amount of time you spend using the LMS; the number of times you return to the LMS; and whether and when you add a contact, join a group, write a post, share a link, post a picture or video, add notes, and/or upload content; and whether you open, forward, or click-through emails.
- Third Party Service Providers.
We may use third party service providers to support our LMS. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, or Flash cookies to receive, collect, and store information.
- Information Collected from Other Sources
- Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through the LMS, as well as information collected from third party sources (including your professors) to help us provide services through the LMS, tailor our communications to you, and to improve the LMS.
- Tracking Options and California Do Not Track Disclosures.
Certain parts of the LMS require cookies. You may adjust your browser or operating system settings to limit certain tracking or to decline cookies; however, if you do so, you may be unable to access certain areas or use certain features of the LMS. Check the “Help” menu of your browser or operating system to learn how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising.
- How We Use Your Information
In its capacity as a technology service provider to the School, 2U may use the information it collects from and about you:
- To provide our services, including the set-up and management of accounts and profiles;
- To develop new products or services and to conduct analysis to enhance current products and services;
- To communicate with you related to your use of the LMS or to your participation in the Program. You may not opt out of receiving such communications while participating in the Program;
- To integrate your use of the LMS with select services provided to you by Google;
- To personalize your experience on the LMS and help us better respond to your individual needs;
- To review the usage and operations of the LMS and to analyze and improve the LMS (we continually strive to improve the LMS based on the information and feedback we receive from you);
- To respond to your inquiries or contact and communicate with you when necessary;
- To protect the security of the LMS; and
- As otherwise described at the point of collection or for purposes which you expressly permit us to use the information.
We will retain your personal information for as long as necessary to provide you with the services through the Website or to otherwise administer and maintain the services and our Website.
- How We Disclose Your Information
2U may share your information with other entities or individuals outside of 2U in the following limited circumstances:
- School: We may share your information with the School in order to process your information, track your participation in the Program, and/or provide our services to the School.
- Service Providers: We may share information with our service providers that provide business, professional, or technical support functions for us. These service providers are only provided access to your information to the extent necessary to process your information and/or provide services to 2U, and may not use or share your information for any other purposes.
- Fraud; Security: We may access and disclosure your information to detect, prevent, or otherwise address fraud, security or other technical issues.
- Consent; Other: We may share information with third parties when we have your consent, or otherwise as described to you at the point of collection.
- Aggregate or Anonymous Non-Personal Information. 2U may also share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses. For example, we provide Google Analytics with de-identified data so that they may provide us with a better understanding of visitors’ interactions with the LMS, including actions a visitor takes while accessing the LMS or sites to which a visitor navigates after leaving the LMS. Learn more about Google Analytics’ use of de-identified data External link .
- Third Party Transfers. We transfer personal data from the European Economic Area to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. In these instances, we use Standard Contractual Clauses, and some of our Service Providers may rely on Standard Contractual Clauses, Privacy Shield, or Binding Corporate Rules, to help ensure we and our Service Providers respect your data privacy rights and protect your data. If you would like a copy of our Standard Contractual Clauses, you may do so by contacting us at firstname.lastname@example.org.
- Your California Privacy Rights
If you are a California resident, you may opt-out of our disclosure of personal information to third parties (including affiliated third parties which may not share the 2U name) for their direct marketing purposes. To opt-out, please contact us at privacy@2U.com External link . You must put the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Non-affiliated third parties are independent from 2U and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.
- Your Rights Under the Family Educational Rights and Privacy Act
You have specific rights relating to the disclosure of any personal information that you provide to us and/or records that we may create about you under the Family Educational Rights & Privacy Act (“FERPA”). You also have specific rights related to accessing and/or updating your personal information. For more information related to the applicability of FERPA and your rights under it, please contact us at privacy@2U.com External link or the appropriate party at the School.
- Public Forums; Publicly Available Content
Any information you may disclose through the LMS, on message boards, in chat rooms, or on other public areas on the LMS may be viewed by others, such as your classmates and professors. Please exercise caution when disclosing personal information in these public areas.
- Data Security
We are committed to protecting the security of your information. We have taken certain physical, administrative, and technical steps designed to safeguard and secure your information and to prevent unauthorized access, maintain accuracy, and ensure appropriate use of your information. The accuracy, safety, and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the LMS, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. Even though we do our best to protect your information, the transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any circumvention of any privacy settings or security measures or unauthorized access to your information.
- Other Websites
We may link to or offer some of our services in connection with third party websites or applications, which may have different privacy practices. We are not responsible for the practices of such sites or applications, and we encourage you to read and fully understand their privacy policies.
- Children’s Privacy
We do not direct the LMS to, nor do we knowingly collect any personal information from, children under 13.
- Accessing and Managing Your Personal Information
You may access and/or update your personal information through your user profile. In some instances, you may be eligible to (a) request that 2U export a full listing of your personal information in a commonly used electronic form (b) withdraw your consent to 2U for processing your personal information; and (c) request that 2U restrict processing or delete your information. Certain personal information, however, is necessary for us to provide information to you about the Program or to provide services to you through the LMS or otherwise. If you choose not to provide this personal information or request that 2U delete or restrict processing of this personal information, you may not be able to participate in the Program, and we may not be able to provide you with other services, including those provided through the LMS or advertised about the Program.
To the extent the above rights apply in your country, they may be limited in some situations, for example, where 2U is under a legal requirement to retain certain information. If you wish to make a request described in this paragraph, or if you are otherwise unable to access and/or edit your personal information through your user profile, you may contact us at privacy@2U.com External link .
- Contact Us