Master of Arts in Counseling and Guidance and Master of Science in Communicative Sciences and Disorders Online Campus Privacy Policy

Last modified: July 27, 2016

OUR COMMITMENT TO PRIVACY

2U, Inc. (“2U” or “Company”) is as a technology service provider for New York University (the “School”) regarding the Master of Arts in Counseling and Guidance and Master of Science in Communicative Sciences and Disorders online programs (the “Programs”). As part of the services 2U provides to the School in connection with the Programs, 2U operates and hosts the 2NYU online campus (the “Website”). 2U respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from you when you visit and use the Website. This Privacy Policy also explains how 2U may use and disclose such information, as well as your ability to control certain uses of it.

INFORMATION COLLECTION

Information You Provide

Except for information automatically collected, 2U collects information from you when you choose to provide it to us. This may include when you register for the Programs, create or update your account profile, upload content, or otherwise contact us.

The information we collect may include your name, address (e.g., city and state), email address, telephone number, birthday, uploaded content (such as academic coursework), and the content of any communications to us.

Information Automatically Collected

We may use cookies or other technologies to collect certain information when you visit or use the Website or interact with the Programs’ emails. For example, we may automatically collect certain non-personal information from you, such as your internet protocol (“IP”) address, browser type, operating system, device identifier, device model, software version, mobile or ISP carrier information, and the domain name from which you accessed the Website.

We also may collect information about your use of the Website, including the times and dates you access the Website; the areas or pages of the Website that you visit; the amount of time you spend using the Website; the number of times you return to the Website; 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.

Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline cookies; however, if you do so, you may be unable to access certain areas of the Website. Check the “Help” menu of your browser or operating system to learn how to change your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies and your choices about not having this information used by certain Service Providers (defined below), please click here. 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. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Information Collected from Other Sources

We may obtain information about you from other sources, including those that you may use to connect to the Website. This information may include your Google account credentials. Any Google account information provided will be stored in a secure and encrypted format.

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 our Website, as well as information collected offline or from third party sources, to help us tailor our communications to you and to improve the Website.

INFORMATION USE

In its capacity as a technology service provider to the School, 2U may use the information it collects from and about you:

Any content you upload to the Website may be made available, and may be accessed, viewed, stored, collected, or used by other users of the Website, such as your classmates and professors, subject to your restrictions and the Website Terms of Use Policy, available here and incorporated herein by reference (see Section 6, “User-Contributed Content”). If you do not want 2U to store metadata associated with your uploaded content, please remove the metadata before uploading the content.

You are responsible for the content you upload and submit to the Website.THE CONTENT YOU UPLOAD OR SUBMIT SHALL NOT INCLUDE PERSONAL HEALTH INFORMATION (“PHI”) OR PERSONAL INFORMATION (“PI”) OF PATIENTS, SUCH AS PATIENT NAMES. BEFORE YOU UPLOAD OR SUBMIT ANY INFORMATION, PLEASE REVIEW AND REDACT ANY PHI OR PI OF PATIENTS.

You acknowledge and agree that 2U has no obligation to pre-screen the information that you submit to 2U. By transmitting or submitting any information you affirm, represent and warrant that such transmission or submission does not contain PHI or PI of patients.

The term “Personal Information” means any information which can be used to identify a person including, but not limited to, name, date of birth, mailing address, home phone number, cell phone number, e-mail address, credit card information, and/or Social Security number. “Protected Health Information” means any information of a person related to health or medical status, including, but not limited to, names of doctors, health conditions, medicines, and/or prescription information and history, paired with Personal Information.

INFORMATION DISCLOSURE

2U may share your information with other entities or individuals outside of 2U in the following limited circumstances: (1) with your consent; (2) to our Service Providers (as defined below), if the disclosure will enable them to perform a business, professional, or technical support function for us; (3) to satisfy any applicable law, regulation, legal process, or enforceable governmental request; (4) as necessary, to enforce the applicable Terms of Use, including investigation of potential violations thereof; (5) to detect, prevent, or otherwise address fraud, security or technical issues; (6) to protect against imminent harm to the rights, property, or safety of 2U, the Website users, or another third party, as required or permitted by law; and (7) as described to you at the point of collection.

2U may also share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.

2U may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through this Website in a manner that is consistent with this Privacy Policy.

YOUR RIGHTS UNDER THE FAMILY EDUCATION 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 Education 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 or the appropriate party at the School.

SERVICE PROVIDERS

We contract with third parties to perform functions related to the Website (“Service Providers”). These Service Providers are only provided access to your information to the extent necessary to process your information and/or provide services to 2U. Service Providers may not use or share your information for other purposes.

OUR COMMITMENT TO DATA SECURITY

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect from and about Website visitors and users, we have put appropriate physical, electronic, and managerial procedures into place to safeguard and secure that information.

The accuracy, safety, and security of your information also depend on you. You are responsible for keeping your Website account password confidential. We ask that you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee our security measures. We are not responsible for circumvention of any privacy settings or security measures.

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.

OUR COMMITMENT TO CHILDREN’S PRIVACY

Protecting the privacy of children under the age of 13 is especially important to us. For that reason, we do not direct the Website to, nor do we knowingly collect any personal information from, children under 13.

ACCESSING AND UPDATING PERSONAL INFORMATION

You may access and/or update your personal information through your user profile. If you are unable to access and/or edit your personal information through your user profile, please contact us at privacy@2u.com.

CHANGES TO THIS PRIVACY POLICY

Please note that we may revise this Privacy Policy at any time and without prior notice. When we do, we will post the change(s) on the Website. In the event that we make any material change(s), we will provide appropriate notice to you. You are responsible for ensuring that we have a current, active, and deliverable email address for you. We recommend that you periodically review this Privacy Policy for any updates and/or changes. Your continued use of the Website after we make changes is deemed to be acceptance of those changes.

HOW TO CONTACT US

We regularly review our compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy, or the practices described herein, to us at Privacy Officer, 8201 Corporate Drive, Suite 190, Landover, MD 20785 or privacy@2U.com.