Last Modified: April 16, 2021
Quick Guide to Contents
Collection of Information
Information You Provide
Trilogy collects information from you when you choose to provide it to us. For example, we collect your information when you submit a webform requesting information about Trilogy-powered Programs, or otherwise contact us or provide information to us through the Website. The information we collect includes personal information – such as your name, address, e-mail address, telephone number, and the content of any communications that we exchange – as well as non-personal information when you:
Information Automatically Collected
Tracking Options and Do Not Track Disclosures
Information Collected from Other Sources
Where permitted by law, we collect or receive information about you from the School (as defined below), your employer, companies to which you indicate that you would like to learn more about the Program, Trilogy’s parent company, 2U, Inc., or other entities within the 2U family of companies (collectively “Other Sources”) in order to update or supplement the information that you provide or that we collect automatically, as described above in Information Automatically Collected. We 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 combine the information we receive from and about you via the Website and from Other Sources to help us tailor our communications to you and to improve the Website.
Failure to Provide Personal Information
Failure to provide certain information may make it difficult or impossible for you to access some services through the Website. 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 the Program.
We do not direct the Boot Camp Service to, nor do we knowingly collect any personal information from, children under the age of 16.
How We Use Your Information
Purposes for Collecting and Processing Personal Information
We process personal information under the following legal bases:
We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests described above. For more details on the balancing tests we have carried out, please contact us at email@example.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 outset of this policy.
Processing Information at the Direction of the School
In some instances, Trilogy may collect and process your personal information at the direction of the School, for instance processing certain of your application materials or applicable loan documentation from the School.
Use of De-identified, Aggregate or Anonymized Information
How We Disclose Your Information
Trilogy shares your information with other entities or individuals in the following limited circumstances:
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 any parts of the Website, 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.
We retain your personal information for as long as we have a relationship with you. We also may retain your personal information for longer period of time which enables us to:
Accessing and Managing Your Personal Information
If you have created a profile after enrolling in a Program, you may access your personal information through your user profile.
In some instances, you may be eligible to (a) ask us for a copy of your personal information; (b) correct, delete, or restrict processing of your personal information; and/or (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.
Your rights regarding your personal information may be limited, 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 the relevant exemption upon which we rely when responding to any request you make.
Our use of certain personal information is necessary for us to provide information to you about the Program or to provide services to you through the Website or otherwise. If you choose not to provide this personal information or request that Trilogy delete or restrict the 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 Website or advertised about the Program.
If you wish to access or delete your information as described in this section, please fill out Trilogy’s Data Request Form. If you believe your rights regarding your personal information have been infringed upon, please contact us firstname.lastname@example.org. For individuals located in the United Kingdom, EEA or Switzerland who have unresolved concerns, you also have a right to lodge a complaint with your applicable Data Protection Authority.
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 also may have specific rights under FERPA related to accessing and/or updating your personal information. Certain information 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 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 Trilogy at the direction of the School and will not be used for targeted advertising.
NOTICE FOR CALIFORNIA CONSUMERS
Categories of Personal Information that We Collect and Disclose
As required by the California Consumer Privacy Act (“CCPA”), below are the categories of personal information about California consumers that Trilogy collects and discloses for a business purpose.
We collect and disclose for a business purpose the following categories of personal information:
Categories of Sources of Personal Information
The categories of sources of personal information we collect are described in the section Collection of Information above.
Purposes for Collecting Personal Information
We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Information above.
Categories of Third Parties with Which Personal Information is Shared
We share the categories of personal information identified above with the following categories of third parties:
In some cases, we share Identifiers and Usage Data with business partners in order to deliver ads that are more relevant to you and to measure and report on the effectiveness of our advertising campaigns. Under the CCPA, some of this data sharing may be broadly considered a “sale” of information, even though these activities do not fit what most people would understand “sale” to mean. Except for this type of sharing, we do not sell your information. To opt out of the sale of your personal information, please visit Trilogy’s Do Not Sell My Information page.
California Consumer Rights
California law gives California consumers the right to make the following requests:
You can submit a copy, deletion, or right-to-know request online by filling out Trilogy’s Data Request Form or by contacting us at 1-888-213-3391. To opt out of the sale of your personal information, please visit Trilogy’s Do Not Sell My Information page.
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.
California’s Shine the Light Law. If you are a California resident and do not want Trilogy to disclose your information to third parties (including to affiliates within the 2U family of companies) for their direct market marketing purposes, you may opt out here.
Public Forums; Publicly Available Content
Any information you may disclose through the Website on message boards, in chat rooms, or on other public areas, such as on webinars that you may attend about the Program, may be viewed by others, including your classmates and learning facilitators. Please exercise caution when disclosing personal information in these public areas. If you do not want Trilogy to store metadata associated with your content, please remove the metadata before uploading your content.
To make a request to delete or access personal data, or for more information about the personal data Trilogy has about you, use Trilogy’s Data Request Form.