2U Digital Campus Privacy Notice

Effective Date: Mar 13, 2026

Introduction

2U, LLC ("2U," "we," or "us"), located at 2345 Crystal Drive, Suite 100, Arlington, Virginia 22202, United States, partners with universities (each, a "School") to provide this 2U-powered online program (the "Program"). This privacy notice (the "Privacy Notice") describes how 2U collects, uses, and discloses information from and about you when you participate in the Program via the learning management system (the "Learning Management System"), as well as your ability to control certain uses of that information. This notice also provides required disclosures under applicable law and serves as 2U's Notice at Collection under the California Privacy Rights Act (see "Additional Legal Disclosures" section below).

2U shares your personal information collected via the Learning Management System with the School. To learn how the School processes your personal information, please review their privacy notice.

Collection of Information

Information You Provide

2U collects and processes personal information about you, such as your name, address, e-mail address, telephone number, prior educational background, assignments that you submit via the Learning Management System, and the content of any communications that we exchange when you interact with the Learning Management System, including when you:

submit information about yourself in the Learning Management System;
interact with content on the Learning Management System;
contact us, or provide information to us, through the Learning Management System or otherwise;
create an account;
participate in our surveys;
communicate with us, for example by submitting queries regarding the LMS or a Program;
use the Learning Management System; and
as directed by the School, such as when you complete class assignments and exams.

In some cases, we require your personal information in order to perform a contract or to comply with a legal obligation.

Failure to provide certain information may make it difficult or impossible for you to access some aspects of the Learning Management System. You should ensure that personal information submitted to us is accurate and up to date. For example, we need a current email address to communicate with you about your Program.

Information We Collect Automatically

When you use the Learning Management System or interact with emails that we send to you, we use cookies and other types of digital trackers to store your preferences, enable you to sign in, provide personalized content, combat fraud, and analyze how the Learning Management System performs. We do not use these cookies for targeted advertising or marketing purposes. These cookies collect information about:

your device and browser, including internet protocol address ("IP address"), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information; and
your interactions with the Learning Management System, including the date and time of your visit, your activity on the Learning Management System, and your clicks on content and emails.

Information Collected from Other Sources

We combine personal information we receive from you with information from other sources including:

The School providing your Program;
online platforms with which you interact;
third parties that are our partners; and
2U, LLC's affiliated companies.

How We Use Your Information

We process your personal information and aggregated or anonymized information derived from your personal information for the following purposes:

To fulfill a contract or take steps linked to a contract, including:
- setting up and managing profiles on the Learning Management System. To do this, we use information you provide when you interact with the Learning Management System. For example, your name, student ID, email address, course enrollments, and information collected from other sources (e.g., from the School, to verify your enrollment status or transfer academic credits);
- communicating with you and responding to your requests, comments, or complaints. To do this, we use your name, e-mail address, telephone number, and the content of any communications that we exchange; and
- protecting the security and functionality of the Learning Management System. To do this, we use information you have provided to us (e.g., user reviews), information we collect automatically through cookies and other digital trackers (e.g., about the pages you visit and your interactions with them), and information collected from other sources (e.g., your complaints about the Learning Management System or our products and services).
To provide the Learning Management System, in accordance with our legitimate interests in providing your online learning experience, 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. Providing our Services is also in the interests of the School and our other partners. This includes:
- providing products and services you have requested, and responding to any comments or complaints you may send us. To do this, we use the information you provide when you interact with the Learning Management System, including the content of any communications that we exchange;
- developing new products or services, or conducting analyses to enhance current products and services. To do this, we use information you provide when you interact with the Learning Management System (e.g., interaction with certain content, posts on discussion boards, attendance of certain events, and feedback you provide through surveys); and information collected from other sources (e.g., information you provide to the School, or where you log in via another online platform);
- in certain instances, where consent is not required by applicable law, to send you direct marketing messages (e.g., emails, SMS messages, telephone calls, and postal mail). These messages may relate to our products and services, and those provided by 2U, LLC's affiliated companies. To do this, we use your name, e-mail address, telephone number, postal address, and information about the Program(s) in which you have expressed an interest;
- reviewing the usage and operations of the Learning Management System, and analyzing and improving the Learning Management System. To do this, we use any feedback you provide about the Learning Management System (directly or through others);
- contacting you for legitimate business purposes. To do this, we use your name, e-mail address, telephone number, and the content of any communications that we exchange;
- using personal information to invite you to take part in market research. To do this, we use your name and contact details, and your participation in the research is entirely voluntary;
- personalizing your experience on the Learning Management System and in any Program in which you choose to enroll, and helping us to better respond to your individual needs. To do this, we use information you provide us about your preferences (e.g., your language preferences), and information collected through cookies and digital trackers (e.g., to track usage, assist with error management, and storing preferences);
- protecting the security and functionality of the Learning Management System. To do this, we use information you have provided to us (e.g., user reviews), information we collect automatically through cookies and other digital trackers (e.g., about the pages you visit and your interactions with them), and information collected from other sources (e.g., complaints about your actions on the Learning Management System); and
- through our use of AI systems. We use AI systems in phone calls, web interactions, chat bots, assistants, and for internal business purposes. When we use AI systems to interact with you, we provide a prominent notice to indicate that you are engaging with an AI.
Where you give us consent. This includes:
- developing new products or services, or conducting analyses to enhance current products and services. To do this, we use information collected through cookies and digital trackers (e.g., information about how users use our Learning Management System, to assist with error management, and to store preferences);
- reviewing the usage and operations of the Learning Management System, and analyzing and improving the Learning Management System. To do this, we use information collected through cookies and digital trackers (e.g., information about error reports, or information about pages that users dwell on for a long time, which suggests they are confusing); and
- other occasions where we ask you for consent, using the data for the purpose which we explain at that time.
To comply with legal obligations, including:
- responding to requests by government or law enforcement authorities. The categories of data used for these purposes will depend on the request; and
- managing legal claims, and ensuring compliance with applicable law and our policies. The categories of data used for these purposes will depend on the nature of the claim, or applicable law or policy; and
At the direction of the School, where applicable.

How We Disclose Your Information

2U shares your information with other entities or individuals in the following circumstances:

1. The School: Subject to our contract with the School, we share the information you provide to us (such as your participation in the Program, your academic materials, your assignments, and your preliminary grade information) with the relevant School in order to fulfill our contracted responsibilities to the School. Once 2U shares your information with the School, 2U does not maintain control over the School's use of your information. 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 notice.

2. 2U, LLC and its affiliates: Where you have expressed interest or given your consent, we share your information with 2U, LLC's affiliated companies to provide you with information about our other educational programs. You may opt out of these communications at any time.

3. Service Providers: We share your information with third parties that provide services on our behalf, including providers of website hosting and maintenance, courier, certification, business operations, and ID verification services ("Service Providers"). Where we share personal information with Service Providers, we do so pursuant to a contract with provisions ensuring your personal information is handled in accordance with this Privacy Notice and applicable law. These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to 2U under that contract, and they are prohibited from using or sharing your information for any other purposes.

4. Your Employer, Sponsor, or their Designee: We share personal information with your employer or sponsor, or someone designated by them, in the event that such third party is paying for your Program. This allows us to fulfill our contractual obligations to your employer, sponsor, or their designee. Information disclosed in this case shall include Program performance information, unless otherwise expressly agreed in writing with 2U.

5. Legal Matters; Safety: We will disclose your information to third parties if required to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; to enforce our legal rights; or otherwise as required by law. We will also disclose your information, as necessary, if we believe that there has been a violation of our Terms of Use (including investigation of potential violations thereof), any other legal document or contract related to the Learning Management System, or the rights of any third party.

6. Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security, or other technical issues.

7. Notice/Consent: We share information with third parties when we have your consent, or when we have explicitly notified you about this sharing when we collect the relevant personal information.

8. Sale or Transfer of Business or Assets: 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 your information in a manner that is consistent with this Privacy Notice. Using your data in this way allows us to fulfill the purposes required by law.

9. International Transfers: We may transfer personal information from your location to other countries where our employees and/or servers are located, including, as applicable, Australia, Canada, the European Economic Area ("EEA"), Mexico, South Africa, the United Kingdom ("UK"), and the United States. Where we transfer your personal information outside of the country where you are located, we put safeguards in place to protect that information. In particular, where we transfer personal data from the EEA or the UK, we transfer it to countries that are deemed to provide an adequate level of protection by the European Commission (i.e., Canada, the UK, the EEA, and the United States (to the extent the recipient is certified to the Data Privacy Framework)). Where we transfer data from the EEA or the UK to other countries (including to the United States where the recipient is not certified to the Data Privacy Framework), we use approved contractual mechanisms to do so. You can request a copy of the relevant mechanism by contacting us at privacy@2u.com.

Information Security

We design our products with appropriate physical, electronic, and managerial procedures 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 Learning Management System, 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 unauthorized access to, or acquisition of, your information.

Data Retention

We retain your personal information for as long as we have a relationship with you. We also may retain your personal information for a longer period of time to enable us to:

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; and/or
support our legitimate interests, as described in this Privacy Notice.

Your Privacy Choices and Rights

2U provides you with various options to exercise your privacy choices and rights:

Once you create a profile on the Learning Management System, you may access and/or update your personal information through your user profile.
If you want to withdraw your consent to our use of cookies that collect your information automatically for the purposes outlined above, you can do so through the "Your Privacy Choices" link in the footer of the Learning Management System.
If you wish to exercise your privacy rights, including rights to access, correct, amend, restrict, or delete your personal information, or object to the processing of your personal information, please fill out 2U's Data Request Form.
If you believe your rights regarding your personal information have been infringed upon, please contact us at privacy@2u.com.
Individuals in certain jurisdictions - including the EEA, Brazil, the People's Republic of China, South Africa, Switzerland, or the UK - have the right to lodge a complaint with the data protection authority in the country where they live.

If you reside in the EU, you can contact our EU representative at DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland, privacy@2u.com. If you reside in the UK, you can contact our UK representative at 2U Group (UK) LTD, ℅ Skadden, Arps, Slate, Meagher & Flom (UK) LLP, 22 Bishopsgate, London, United Kingdom, EC2N 4BQ, +44 20 3457 5774.

A list of 2U data controllers can be found here. The relevant data controller will be charged with making decisions regarding the purposes and methods of processing of data under the terms of this Privacy Notice.

Additional Information

Education Records

You may have specific rights relating to the disclosure of any personal information that you provide to us, and/or education records that we may create about you, under the Family Education Rights & Privacy Act ("FERPA"). You may also have specific rights under FERPA related to accessing and/or updating your personal information. Certain records may be excluded from education records made available for inspection, in accordance with applicable law and our confidentiality obligations with third parties. You may also request amendment of education records that you believe are inaccurate, misleading, or in violation of your rights. If you would like to inspect and review your education records pursuant to FERPA, you may submit a request to the School's FERPA office. Any FERPA-protected information will be processed by 2U at the direction of the School, and will not be used for targeted advertising.

Children's Privacy

We do not direct the Learning Management System to, nor do we knowingly collect any personal information from, children under the age of 16.

Public Forums; Publicly Available Content

Any information you may disclose through the Learning Management System — such as on message boards, in chat rooms, or on other public areas of the Learning Management System — may be viewed by others, such as your classmates and learning facilitators. Please exercise caution when disclosing personal information in these public areas. You are responsible for ensuring the accuracy of all information submitted to the Learning Management System, and you agree to only publish or share information about a third party with the third party's consent.

Your content may be made available, and may be accessed, viewed, stored, collected, or used by other users of the Learning Management System, such as your classmates and faculty, subject to your restrictions and the Terms of Use. If you do not want 2U to store metadata associated with your content, please remove the metadata before uploading your content.

Third-Party Content, Links, and Plug-Ins

The Learning Management System may also offer you the ability to interact with content provided by third parties not affiliated with 2U ("Third-Party Content"). Third-Party Content linked to or embedded on the Learning Management System is governed by the privacy policies of those third parties. Your use of Third-Party Content is subject to each site's privacy notice, which may be different from ours. We have no control over the information that is collected, stored, or used by Third Party Content.

Questions or Concerns About this Privacy Notice

You may direct any questions or concerns regarding this Privacy Notice to us at privacy@2u.com. You may also write to us at ATTN: Privacy, 2U, LLC 2345 Crystal Drive, Suite 1100, Arlington, VA 22202.

We review this Privacy Notice from time to time and reserve the right to make changes to this Privacy Notice at any time. If we make material changes, we will give notice via the Learning Management System features or by otherwise notifying you.

Additional Legal Disclosures

CCPA

As required by the California Consumer Privacy Act ("CCPA"), below are the categories of personal information about California consumers that we collect and disclose to provide the Learning Management System, and operate our business:

Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
Commercial Information, including records of products and services purchased, and purchasing history.
Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, or medical information relevant to your participation in the Program.
Usage Data, including internet or other electronic network activity information, such as information about how you interact with our services or advertisements.
Audio, electronic, visual, thermal, olfactory or similar information, including voice recordings when you call us.
Biometric Information, including facial recognition used for identity verification, where required by the School and/or remote proctoring.
Employment History, including professional or employment-related information.
Education Information, including information about education history or background.
Protected Classifications, characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, and citizenship status.
Inferences drawn from any of the information identified above, reflecting your preferences and characteristics.

The categories of sources of personal information we collect are described in the section "Collection of Information" above.

The purposes for collecting personal information are described in the section "How We Use Your Information" above.

We disclose the categories of personal information identified above in the section "How We Disclose Your Information" above.

2U discloses pseudonymized device and browser information, and information about your interactions with the Learning Management System, to advertising companies that we contract with to deliver personalized ads and measure the effectiveness of our advertising campaigns. To the extent these disclosures are considered "selling" or "sharing" under California law, 2U provides you the ability to opt out of these disclosures through the "Your Privacy Choices" link in the footer of the Learning Management System.

2U will retain your Personal Information as identified above in the section "Data Retention".

California law gives California consumers the right to make the following requests:

The right to opt-out of the sale or sharing of your personal information.
The right to request a copy of the personal information that we have collected about you in the prior 12 months.
The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging, or to comply with a legal obligation).
The right to correct inaccurate Personal Information that we maintain about you.
The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources of personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.

You can submit a copy, deletion, correction, or right-to-know request online by filling out 2U's Data Request Form or by contacting us at 1-888-213-3874.

You may authorize another person (your "authorized agent") to submit a request on your behalf through the methods described above. Your authorized agent should submit proof that you gave the agent signed permission to submit the request. We may still require you to directly verify your identity, and directly confirm that you have provided the authorized agent permission to submit the request.

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. We do not discriminate if you exercise your rights under the CCPA.

2U does not use or disclose your sensitive personal information for purposes other than those set forth in the CCPA.

California's Shine the Light Law

If you are a California resident and do not want 2U to disclose your information to third parties (including to affiliates of 2U, LLC or the School) for their direct marketing purposes, you may opt out here.

View the previous version of this Privacy Notice.