QUICK GUIDE TO CONTENTS
- Collection of Information
- How We Use Your Information
- How We Disclose Your Information
- Information Security and Data Retention
- Your Rights Regarding Your Personal Information
- Additional Information
Collection of Information
Information You Provide
We do not direct the Website to, nor do we knowingly collect any personal information from, children under 16.
Information Automatically Collected
Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline or delete Cookies, but by doing so you may be unable to access or use certain areas of the Websites. Check the “Help” menu of your browser or operating system to learn how to change your tracking settings or Cookie 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. 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 collect or receive information about you from other sources with which you interact (e.g., Facebook), companies that are our partners, or other entities within the 2U family of companies to update or supplement the information that you provide or that we collect automatically. We may use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services or other offers that may be of interest to you, and for internal business analysis or other business purposes.
Our Combination of Your Information
We may combine the information we receive from and about you, via the Websites and from third parties, to help us tailor our communications to you and to improve the Websites.
Failure to Provide Personal Information
Failure to provide certain information may make it difficult or impossible for you to access some services through the Websites (for example, to register for and complete Courses). You will need to 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 the Course in which you are enrolled.
How We Use Your Information
Legal Basis for Collecting and Processing Personal Information
We process personal information for the following purposes:
- To fulfil 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 GetSmarter’s business and pursue our legitimate interests. This includes:
- using your information to provide products and services you have requested and to respond to any comments or complaints you may send us;
- personalizing your experience on the Websites and in any Course in which you choose to enroll and to help us to better respond to your individual needs;
- using information we collect about you through the Websites to deliver advertising that is targeted for individuals with similar interests or characteristics through 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 Websites and to analyze and improve the Websites (we continually strive to improve the Websites 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.
- To protect the security and functionality of the Websites. This includes:
- 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 data sharing 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 Websites or our products and services.
- 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 GetSmarter, its parent company, 2U, Inc., 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).
We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests, which we have described above.
How We Disclose Your Information
GetSmarter may share your information with other entities or individuals in the following circumstances:
- University Partners: We may share your information with the relevant college or university with which we collaborate on Courses (“University Partner”) in order to process your information, track your participation in the Course, and/or fulfill our contracted responsibilities to the University Partner.
- The 2U Family of Companies: Where you have expressed interest and given your consent, we may share your information with our parent company, 2U, Inc., and within the 2U family of companies to provide you with information about other educational programs.
- Service Providers: We may share your information with our service providers that provide business, professional, or technical support functions for us. In particular, we use third-party providers of website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services. These service providers are only given access to your information to the extent necessary to process your information and/or provide services to GetSmarter, and they are prohibited from using or share your information for any other purposes. GetSmarter may disclose limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.
- Your Employer: We may share your information with your employer, in the event that the employer is paying for your Course. Information disclosed in this case shall include Course performance information, unless otherwise expressly agreed in writing with GetSmarter.
- Fraud; Security: We may access and disclose 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.
- De-Identified Aggregate or Anonymous Information: GetSmarter may also share de-identified aggregate or anonymous 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 Websites, including actions a visitor takes while accessing the Websites or sites to which a visitor navigates after leaving the Websites. Learn more about Google Analytics’ use of de-identified data, and how to opt out of such use with a browser add-on, here. International Transfers: We transfer personal information from the European Economic Area (“EEA”) to other countries, including the United States and South Africa, some of which have not been designated by the European Commission as having an adequate level of data protection. In these instances, we use Standard Contractual Clauses to meet the adequacy requirement. 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 email@example.com or via our contact page.
For California Residents: If you do not want GetSmarter to disclose your information to third parties (including affiliated third parties which may not share the GetSmarter name) for their direct marketing purposes, you may opt out of such disclosure by contacting us at firstname.lastname@example.org or on our contact page.
Information Security and Data Retention
We are committed to protecting the security of your information. We maintain what we believe to be 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 Websites, 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, 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.
Your Rights Regarding Your Personal Information
You may access and/or update your personal information through your user profile.
In some instances, you may have the right under applicable law to: (a) ask us for a copy of your personal information; (b) correct, delete or restrict processing of your personal information; and (c) obtain the personal information you provide to us in a structured, machine readable format. In addition, you may have the right under applicable law to object to the processing of your personal information in some circumstances. If you would like to inquire about your right to object to the processing of your personal information for direct marketing purposes, you may contact us at email@example.com.
Your rights regarding your personal information may be limited in certain circumstances, for example, if fulfilling your request would reveal personal information about another person or would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
Our use of certain personal information is necessary for us to provide information to you about the Course or to provide services to you through the Websites or otherwise. If you choose not to provide this personal information or request that GetSmarter delete or restrict the processing of this personal information, you may not be able to participate in the Course, and we may not be able to provide you with other services, including those provided through the Websites or advertised about the Course.
If you believe your rights regarding your personal information have been infringed upon, please contact us as set forth in the “Additional Information” section below. If you are located in the EEA or Switzerland and have unresolved concerns, you also have a right to lodge a complaint with the applicable data protection authorities.
To the extent the above rights apply in your country, they may be limited in some situations, for example, if GetSmarter is under a legal requirement to retain certain information. If you wish to make a request described in this section, or if you are otherwise unable to access and/or edit your personal information through your user profile, you may contact us at firstname.lastname@example.org or use the Data Enquiry Form.
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”), or other relevant law or regulation. You also may have specific rights under FERPA related to accessing and/or updating your personal information. If you would like to inspect and review your education records, you may submit a request by emailing email@example.com. Requests for access under FERPA will receive a response within 45 days, although certain records may be excluded from education records made available for inspection (within the bounds of the law and our confidentiality undertakings with third parties). You may also request amendment of records that you believe are inaccurate, misleading or in violation of your rights.
Public Forums; Publicly Available Content
Any information you may disclose through the Websites, such as on message boards, in chat rooms, or on other public areas on the Websites, 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 Websites, and you agree to only publish or share information about a third party with the third party’s consent.
Third-Party Content, Links, and Plug-Ins
Changes to This Policy
Questions or Concerns About This Policy
For the purposes of EU law, you can find a list of GetSmarter data controllers here.
For the purposes Article 27 of the General Data Protection Regulation, the representative within the European Union for GetSmarter data controllers not established in the European Union is 2U (UK) LTD C/o Skadden, Arps, Slate, Meagher & Flom (UK) Llp 40 Bank Street, Canary Wharf, London, United Kingdom, E14 5DS, +44 20 3457 5774, firstname.lastname@example.org.
Date of Last Amendment: 31 October 2018