Quick Guide to Contents
Collection of Information
Information You Provide
Information Automatically Collected
Tracking Options and California Do Not Track Disclosures.
Information Collected from Other Sources
Our Combination of Your Information
Failure to Provide Personal Information
How We Use Your Information
Legal Basis for Collecting and Processing Personal Information
- To fulfill a contract or take steps linked to a contract. This includes:
- Providing our services, including the set up and management of accounts and profiles;
- Verifying your identity;
- Taking payments;
- Communicating with you.
- To conduct 2U’s business and pursue our legitimate interests in marketing our business, ensuring that we conduct our business in line with our objectives, improving and developing our products and services, and keeping our records accurate and up to date. This includes:
- using your information to provide products and services you have requested and responding to any comments or complaints you may send us;
- personalizing your experience on the Website and in any Program in which you choose to enroll and to help us to better respond to your individual needs;
- using information we collect through your use of the Website to deliver advertising that is targeted for groups of individuals with similar interests or characteristics through services offered by third party Service Providers, such as Facebook Custom Audiences or other similar business tools;
- developing new products or services or conducting analysis to enhance current products and services;
- reviewing the usage and operations of the Website and to analyze and improve the Website (we continually strive to improve the Website based on the information and feedback we receive from you);
- contacting you for legitimate business purposes;
- using personal information to invite individuals to take part in market research;
- where consent is not required by applicable law, for direct marketing purposes;
- protecting the security and functionality of the Website, including:
- If you provide a credit or debit card as payment, using third parties to check the validity of the sort code or routing number, account number and card number you submit in order to prevent fraud (see “How We Disclose Your Information” below);
- Monitoring customer accounts to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law;
- Using personal information you provide to investigate any complaints received from you or from others about our Website or our products and services.We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests, which we have described above. For more details on the balancing test we have carried out, please contact us at privacy@2U.com. You may also have the right to object to our use of your personal data on the basis of our legitimate interests as described at the start of this policy.
- Where you give us consent. This includes:
- where consent is required by applicable law, sending you direct marketing in relation to our relevant products and services, or other products and services provided by 2U and the 2U family of companies;
- on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.
- For purposes which are required by law. This includes:
- in response to requests by government or law enforcement authorities conducting an investigation;
- using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation.
How We Disclose Your Information
- The School: We share your information with the School in order to process your information (such as your application materials) and/or to fulfill our contracted responsibilities to the School. Once 2U shares your application materials (or, if you are a recommender, your recommendation) with the School, 2U does not maintain control over the School’s use of your application (or recommendation). We also share de-identified aggregate, pseudonymous, or anonymous information with the School for their own research and analytics purposes. The School’s use of your information will be subject to its privacy policies.
- The 2U Family of Companies: Where you have expressed interest and given your consent, we share your information within the 2U family of companies to provide you with information about other educational programs.
- Service Providers: We share your information with third parties that provide business, professional, or technical support functions for us. In particular, we use third-party providers for website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services (“Service Providers”). These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to 2U, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, 2U discloses limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.
- Your Employer: We share your information with your employer, in the event that the employer is paying for your Program. Information disclosed in this case shall include Program performance information, unless otherwise expressly agreed in writing with 2U.
- Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
- Consent; Other: We share information with third parties when we have your consent, or otherwise as described to you at the point of collection.
- International Transfers: We transfer personal information from the European Economic Area (“EEA”) to other countries, including the United States and South Africa. Where information is transferred outside the EEA to a third party in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by Standard Contractual Clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to firstname.lastname@example.org.
Information Security and Data Retention
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under the law;
- Defend or bring any existing or potential legal claims;
- Deal with any complaints regarding the services;
- Enforce our commercial agreements;