Last Modified: October 20, 2020
Quick Guide to Contents
- Collection of Information
- How We Use Your Information
- How We Disclose Your Information
- Information Security and Data Retention
- Accessing and Managing Your Personal Information
- Additional Information
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:
- indicate an interest in the Boot Camp Service (you may unsubscribe from promotional emails by clicking “unsubscribe” on the emails you receive from us);
- create an account;
- register or apply for a Program, either directly with us, through your employer, or through some other means;
- make a payment;
- participate in our surveys, promotions, and competitions;
- sign up for a newsletter;
- post information to the Boot Camp Service that includes personal information;
- use the Boot Camp Service.
In some cases, we require your personal information in order to perform a contract or to comply with a legal obligation.
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, 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.
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:
- To fulfill a contract or take steps linked to a contract, including:
- providing our services;
- verifying your identity;
- taking payments;
- communicating with you.
- To conduct Trilogy’s business and pursue our legitimate interests in marketing our business, 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. This includes:
- using your information to provide products and services you have requested and responding to any comments or complaints you may send us;
- personalizing your experience on the Boot Camp Service and helping us to better respond to your individual needs;
- targeting advertising to groups of individuals with similar interests or characteristics through services offered by third party Service Providers, such as Facebook Custom Audiences or other similar business tools;
- developing new products or services or conducting analyses to enhance current products and services;
- reviewing the usage and operations of the Boot Camp Service and analyzing and improving the Boot Camp Service (we continually strive to improve the Boot Camp Service 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;
- protecting the security and functionality of the Boot Camp Service, including using personal information you provide to investigate any complaints received from you or from others about our Boot Camp Service or our products and services.
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 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.
- 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 Trilogy, Trilogy’s 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.
- Protecting the security and functionality of the Boot Camp Service;
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
How We Disclose Your Information
Trilogy shares your information with other entities or individuals in the following limited circumstances:
- 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.
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.
- 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.
- 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.
- Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
- Consent; Other: We share information with third parties when we have your consent, or otherwise as described to you at the point of collection.
- 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 firstname.lastname@example.org.
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:
- 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;
- Address any complaints regarding the services;
- Enforce our commercial agreements; and
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.
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:
- 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.
- Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, physical characteristics (profile photograph), education, employment, employment history, financial information relevant to your payments, or medical information relevant to your participation in the Boot Camp Services.
- Usage Data, including internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- 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.
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:
- Third-party providers that serve business, professional or technical support functions,
- Trilogy’s parent company 2U, Inc., and the 2U family of companies,
- Your Employer,
- Potential Employers, or
- Third parties for legal matters or safety purposes.
California Consumer Rights
California law gives California consumers the right to make the following requests:
- The right to opt-out of sale of your personal information. Trilogy does not sell 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 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 for 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, 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.
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.
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.