Last Modified: February 23, 2018

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 Arts, Counseling for Mental Health and Wellness online programs (the “Program”). As part of the services 2U provides to the School in connection with the Program, 2U operates and hosts www.counseling.steinhardt.nyu.edu (the “Site”). 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 Site. 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

Except for information automatically collected, 2U collects information from you when you choose to provide it to us. This may include when you request or agree to receive information from us about the Program and programs offered at other schools, provide your information on the Site, or otherwise contact us.

The information we collect may include your name, address, email address, telephone number, your prior education background information (such as your GPA range, level of education, name of prior institution attended and degree earned, if any), and the content of any communications to us.

We may use cookies or other technologies to collect certain information when you visit the Site or interact with 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 Site.

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

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site, as well as information collected offline and/or from third party sources, to help us tailor our communications to you and to improve the Site.

INFORMATION USE

In our capacity as a technology service provider to the School, 2U may use the information we collect from and about you:

In addition, outside of our capacity as a service provider to the School, 2U may use the information we collect from and about you to provide you with information about online programs we think may be of interest to you.

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, Site users, or other third party or parties, as required or permitted by law; (7) to our select partners and affiliates that we believe may have offers of interest to you; and (8) 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 Site in a manner that is consistent with this Privacy Policy.

SERVICE PROVIDERS

We contract with third parties to perform functions related to the Site (“Service Providers”). We only provide these Service Providers access to your information to the extent necessary to process your information and/or provide services to 2U. We do not permit Service Providers to 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 Site visitors and users, we have put what we believe to be 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. Where we have given you (or where you have chosen) a password for access to certain parts of the Site, you are responsible for keeping this password confidential. We ask that you not 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.

LINKS TO OTHER WEBSITES

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 Site to, nor do we knowingly collect any personal information from, children under 13.

OPTING OUT

If you do not want 2U to disclose your personal information to third parties (including affiliated third parties which may not share the 2U name) for their direct marketing purposes, you may opt out of such disclosure by contacting us at privacy@2U.com. Please be aware that any limitations that you may place on the disclosure of your personal information may restrict your ability to use the Site in its entirety.

ACCESSING AND UPDATING PERSONAL INFORMATION

We make every effort to provide you with the ability to request that we correct your personal information stored by 2U if it is inaccurate, or delete such information. You may make such a request by emailing 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 Site. 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 Site 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 Compliance Department/Privacy, 7900 Harkins Road, Suite 501, Lanham, MD 20706 or privacy@2U.com.