Trilogy Privacy Policy

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Last Modified: July 6, 2020

Emerson College (the “School”), in association with Trilogy Education Services, LLC (as owned and operated by 2U, Inc.) located at 105 East 34th Street #225, New York, New York 10016 (“Trilogy,” “we,” or “us”), provides this boot camp (the “Program”). This privacy policy (the “Privacy Policy”) describes how Trilogy collects, uses, and discloses information from and about you when you visit and use the Boot Camp Service (as such term is defined in the Boot Camp Terms), as well as your ability to control certain uses of that information, including your education records – as defined in the Family Educational Rights and Privacy Act (“FERPA”). It also describes certain data protection rights which apply, subject to applicable law, including a right to object to some of the processing which Trilogy carries out. More information about your rights, and how to exercise them, is set out in Accessing and Managing Your Personal Information below. 

Trilogy respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. By accessing or otherwise using the Boot Camp Service, you agree to the terms and conditions of this Privacy Policy, which is incorporated into the Terms of Use, and to Trilogy’s collection, use, and disclosure of your information in accordance with this Privacy Policy, where such agreement is permitted by applicable law. 

We regularly review our compliance with this Privacy Policy. Whenever we receive a formal complaint, we make best efforts to contact the person who made the complaint to attempt to resolve their concerns. If you have any questions about the use of your information, or the contents of this Privacy Policy, please contact us at privacy@trilogyed.com.

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 Boot Camp Service. 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:

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

Information Automatically Collected

When you visit the Boot Camp Service or interact with e-mails that we send to you, we passively collect information from you, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We and our third-party partners use cookies and other technologies to collect information about your visit to the Boot Camp Service, such as the date and time of your visit, the information you searched to find the Boot Camp Service, your activity on the Boot Camp Service, and your clicks on our ads. “Cookies” are small files which may be stored on your computer during your use of the Boot Camp Service and contain data about your use of the Boot Camp Service. We use session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or after a specified expiry date) to understand more about your activity on the Boot Camp Service. 

Please see Trilogy’s Cookie Policy for details about how we use cookies and other tracking technologies and how you can control the cookies set on your browser. 

Tracking Options and Do Not Track Disclosures 

You may adjust your browser or operating system settings to limit tracking or to decline cookies. If you choose to limit tracking or decline cookies, however, you may be unable to access certain areas of the Boot Camp Service. Check the “Help” or “Settings” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. Learn more about the use of cookies or other tracking technologies and your choices regarding the use of information collected this way by certain Service Providers (as defined below). On your mobile device, you can adjust your privacy and advertising settings to limit tracking for advertising or to 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. Please see our Cookie Policy for more information or to opt out.

Information Collected from Other Sources

Where permitted by law, we collect or receive information about you from the School, your employer, companies to whom 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 Boot Camp Service and from Other Sources to help us tailor our communications to you and to improve the Boot Camp Service.

Failure to Provide Personal Information

Failure to provide certain information may make it difficult or impossible for you to access some services through the Boot Camp Services (for example, to register for and complete Programs). 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 in which you choose to enroll.

Children’s Privacy

We do not direct the Boot Camp Service to, nor do we knowingly collect any personal information from, children under the age of 13.


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, which we have described above. For more details on the balancing test we have carried out, please contact us at privacy@trilogyed.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 (as defined below), for instance processing certain of your application materials or applicable loan documentation from the School.

Use of De-identified, Aggregate or Anonymized Information

We use de-identified, aggregate or anonymized information to help us analyze the use of the Boot Camp Service. Where permitted by law, this Privacy Policy does not limit our use or disclosure of de-identified, aggregate, pseudonymous or anonymous information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties in our discretion. 


How We Disclose Your Information

Trilogy shares your information with other entities or individuals in the following limited circumstances: 

  1. The School: We may share your information with School in order to provide the Boot Camp Services, track your participation in the Program, and/or fulfill our contracted responsibilities to the University Partner. Once we share your personal information with the School, Trilogy does not maintain control over the School’s use of your personal 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 is subject to its privacy policy.
  2. The 2U Family of Companies: Where you have expressed interest and given your consent, we share your information within the 2U family of companies to provide you with information about other educational programs.
  3. Service Providers: We share your information with third parties that provide business, professional, or technical support functions for us. In particular, we use third-party providers for website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services (“Service Providers”). These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to Trilogy, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, Trilogy discloses limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.
  4. Your Employer: We share your information with your employer, in the event that the employer is paying for your Program. Information disclosed in this case shall include Program performance information, unless otherwise expressly agreed in writing with Trilogy.
  5. Potential Employers: Where you choose to work with our career services team, we will share your information with potential employers. Information disclosed in this case shall include your resume, employer-ready materials that you prepare (e.g., your portfolio), your LinkedIn profile, or other information that you make available to Trilogy. 
  6. Legal Matters; Safety: We access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We disclose your information to protect the security of the Program, the Boot Camp Service, servers, network systems, and databases. We 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 Boot Camp Service, or the rights of any third party.
  7. Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
  8. Consent; Other: We share information with third parties when we have your consent, or otherwise as described to you at the point of collection.
  9. Sale or Transfer of Business or Assets: Trilogy 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 Policy.
  10. International Transfers: We transfer personal information from the European Economic Area (“EEA”) to other countries, including the United States and South Africa. 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 privacy@trilogyed.com


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 Boot Camp Service, 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 Boot Camp Service 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 Boot Camp Service or advertised about the Program. 

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 Authority.

If you wish to access or delete your information as described in this section, please fill out Trilogy’s Data Request Form.


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 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 University’s FERPA office.

 
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 do not sell personal information.  

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 personal information identified above with the following categories of third parties:

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.  

The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data.  

Public Forums; Publicly Available Content

Any information you may disclose through the Boot Camp Service, such as 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, such as 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. 

Third-Party Content 

The Boot Camp Service may also offer you the ability to interact with content provided by third parties not affiliated with Trilogy (“Third-Party Content”). Third-Party Content linked to or embedded on this Boot Camp Service is governed by the privacy policies of those third parties. Your use of Third-Party Content is subject to each site’s privacy policy, which may be different from ours. We have no control over the information that is collected, stored, or used by Third Party Content.

Changes to this Privacy Policy 

We review this Privacy Policy from time to time and reserve the right to make changes to this Privacy Policy at any time. If we do make material changes, we will give notice via the Boot Camp Service features or by otherwise contacting you.

 
Questions or Concerns About this Privacy Policy 

You may direct any questions or concerns regarding this Privacy Policy to us at privacy@trilogyed.com.

If you live in the European Union, you may have the right to file a complaint with your Data Protection Authority. For the purposes of EU data protection law, you can find a list of Trilogy data controllers 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 Policy.

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.

View Emerson College’s Privacy Policy

View the previous version of this Privacy Policy.