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Promotions Policy



PRIVACY POLICY

This Privacy Policy was last updated on November 11, 2024.

Thank you for joining Udemy. We at Udemy (“Udemy”, “we”, “us”) respect your
privacy and want you to understand how we collect, use, and share data about
you. This Privacy Policy covers our data collection practices and describes your
rights regarding your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy
applies when you visit or use Udemy websites, mobile applications, APIs, or
related services (the “Services”). It also applies to prospective customers of
our business and enterprise products.

By using the Services, you agree to the terms of this Privacy Policy. You
shouldn’t use the Services if you don’t agree with this Privacy Policy or any
other agreement that governs your use of the Services.


TABLE OF CONTENTS

 * 1. What Data We Get
 * 2. How We Get Data About You
 * 3. What We Use Your Data For
 * 4. Who We Share Your Data With
 * 5. Security
 * 6. Your Rights
 * 7. Jurisdiction-Specific Rules
 * 8. Updates & Contact Info


1. WHAT DATA WE GET

We collect certain data from you directly, like information you enter yourself,
data about your consumption of content, and data from third-party platforms you
connect with Udemy. We also collect some data automatically, like information
about your device and what parts of our Services you interact with or spend time
using. All data listed in this section is subject to the following processing
activities: collecting, recording, structuring, storing, altering, retrieving,
encrypting, pseudonymizing, erasing, combining, and transmitting.


1.1 DATA YOU PROVIDE TO US

We may collect different data from or about you depending on how you use the
Services. Below are some examples to help you better understand the data we
collect.

When you create an account and use the Services, including through a third-party
platform, we collect any data you provide directly, including:

Category of Personal Data Description Legal Basis for Processing Account Data In
order to use certain features (like accessing content), you need to create a
user account, which requires us to collect and store your email address,
password, and account settings. To create an instructor account, we collect and
store your name, email address, password, and account settings. As you use
certain features on the site, you may be prompted to submit additional
information. For example, you may choose to provide information relevant to your
learning interests, including occupation and skill interests, and if you apply
to become an instructor, we may collect government ID information, verification
photo, date of birth, race/ethnicity, and phone number. Upon account creation,
we assign you a unique identifying number.
 * Performance of contract
 * Legitimate interests (service provisioning, identity verification, fraud
   prevention and security, communication)

Profile Data You can also choose to provide profile information like a photo,
headline, biography, language, website link, social media profiles, country, or
other data. Your Profile Data will be publicly viewable by others.
 * Performance of contract
 * Legitimate interests (enhanced platform functionality, convey content source
   information)

Shared Content Parts of the Services let you interact with other users or share
content publicly, including by uploading courses and other educational content,
posting reviews about content, asking or answering questions, sending messages
to students or instructors, or posting photos or other work you upload. Such
shared content may be publicly viewable by others depending on where it is
posted.
 * Performance of contract
 * Legitimate interests (service provisioning, enhanced platform functionality)

Learning Data When you access content, we collect certain data including which
courses, assignments, labs, workspaces, and quizzes you’ve started and
completed; content and subscription purchases and credits; subscriptions;
completion certificates; your exchanges with instructors, teaching assistants,
and other students; and essays, answers to questions, and other items submitted
to satisfy course and related content requirements.
 * Performance of contract
 * Legitimate interests (service provisioning, enhanced platform functionality)

Student Payment Data If you make purchases, we collect certain data about your
purchase (such as your name, billing address, and ZIP code) as necessary to
process your order and which may optionally be saved to process future orders.
You must provide certain payment and billing data directly to our payment
service providers, including your name, credit card information, billing
address, and ZIP code. We may also receive limited information, like the fact
that you have a new card and the last four digits of that card, from payment
service providers to facilitate payments. For security, Udemy does not collect
or store sensitive cardholder data, such as full credit card numbers or card
authentication data.
 * Performance of contract
 * Legal obligation
 * Legitimate interests (payment facilitation, fraud prevention and security,
   compliance)

Instructor Payment Data If you are an instructor, you can link your PayPal,
Payoneer, or other payment account to the Services to receive payments. When you
link a payment account, we collect and use certain information, including your
payment account email address, account ID, physical address, or other data
necessary for us to send payments to your account. In some instances, we may
collect ACH or wire information to send payments to your account. In order to
comply with applicable laws, we also work with trusted third parties who collect
tax information as legally required. This tax information may include residency
information, tax identification numbers, biographical information, and other
personal information necessary for taxation purposes. For security, Udemy does
not collect or store sensitive bank account information. The collection, use,
and disclosure of your payment, billing, and taxation data is subject to the
privacy policy and other terms of your payment account provider.
 * Performance of contract
 * Legal obligation
 * Legitimate interests (service provisioning, payment facilitation, fraud
   prevention and security, compliance)

Data About Your Accounts on Other Services

We may obtain certain information through your social media or other online
accounts if they are connected to your Udemy account. If you login to Udemy via
Facebook or another third-party platform or service, those platforms and
services make information available to us through their APIs. The information we
receive depends on what information you (via your privacy settings) or the
platform or service decide to give us and usually consists of your first and
last name, user identification number, and email address.

If you access or use our Services through a third-party platform or service, or
click on any third-party links, the collection, use, and sharing of your data
will also be subject to the privacy policies and other agreements of that third
party.

 * Legitimate interests (identity verification, user experience improvement)

Sweepstakes, Promotions, and Surveys We may invite you to complete a survey or
participate in a promotion (like a contest, sweepstakes, or challenge), either
through the Services or a third-party platform. If you participate, we will
collect and store the data you provide as part of participating, such as your
name, email address, postal address, date of birth, or phone number. That data
is subject to this Privacy Policy unless otherwise stated in the official rules
of the promotion or in another privacy policy. The data collected will be used
to administer the promotion or survey, including for notifying winners and
distributing rewards. To receive a reward, you may be required to allow us to
post some of your information publicly (like on a winner’s page). Where we use a
third-party platform to administer a survey or promotion, the third party’s
privacy policy will apply.
 * Performance of contract
 * Legitimate interests (promotions administration, prize delivery, compliance)

Communications and Support If you contact us for support or to report a problem
or concern (regardless of whether you have created an account), we collect and
store your contact information, messages, and other data about you like your
name, email address, messages, location, Udemy user ID, refund transaction IDs,
and any other data you provide or that we collect through automated means (which
we cover below). We use this data to respond to you and research your question
or concern, in accordance with this Privacy Policy.
 * Legitimate interests (customer and technical support)

The data listed above is stored by us and associated with your account. Udemy’s
use and transfer to any other app of information received from Google APIs, like
instructor uploaded content, will adhere to Google API Services User Data
Policy, including the Limited Use requirements.


1.2 DATA WE COLLECT THROUGH AUTOMATED MEANS

When you access the Services (including browsing content), we collect certain
data by automated means, including:

Category of Personal Data Description Legal Basis for Processing System Data
Technical data about your computer or device, like your IP address, device type,
operating system type and version, unique device identifiers, browser, browser
language, domain and other systems data, and platform types.
 * Performance of contract
 * Legitimate interests (service provisioning, customer and technical support,
   fraud prevention and security, communication, product improvement)

Usage Data Usage statistics about your interactions with the Services, including
content accessed, time spent on pages or the Service, pages visited, features
used, your search queries, click data, date and time, referrer, and other data
regarding your use of the Services.
 * Legitimate interests (service provisioning, user experience improvement,
   product improvement)

Approximate Geographic Data An approximate geographic location, including
information like country, city, and geographic coordinates, calculated based on
your IP address.
 * Legitimate interests (user experience improvement, fraud prevention and
   security, compliance)

The data listed above is collected through the use of server log files and
tracking technologies, as detailed in the “Cookies and Data Collection Tools”
section below. It is stored by us and associated with your account.


1.3 DATA FROM THIRD PARTIES

If you are a Udemy Business enterprise or corporate prospect, in addition to
information you submit to us, we may collect certain business contact
information from third-party commercial sources.


2. HOW WE GET DATA ABOUT YOU

We use tools like cookies, web beacons, and similar tracking technologies to
gather the data listed above. Some of these tools offer you the ability to opt
out of data collection.


2.1 COOKIES AND DATA COLLECTION TOOLS

We use cookies, which are small text files stored by your browser, to collect,
store, and share data about your activities across websites, including on Udemy.
They allow us to remember things about your visits to Udemy, like your preferred
language, and to make the site easier to use. To learn more about cookies, visit
https://cookiepedia.co.uk/all-about-cookies. We may also use clear pixels in
emails to track deliverability and open rates.

Udemy and service providers acting on our behalf (like Google Analytics and
third-party advertisers) use server log files and automated data collection
tools like cookies, tags, scripts, customized links, device or browser
fingerprints, and web beacons (together, “Data Collection Tools“) when you
access and use the Services. These Data Collection Tools automatically track and
collect certain System Data and Usage Data (as detailed in Section 1) when you
use the Services. In some cases, we tie data gathered through those Data
Collection Tools to other data that we collect as described in this Privacy
Policy.


2.2 WHY WE USE DATA COLLECTION TOOLS

Udemy uses the following types of Data Collection Tools for the purposes
described:

 * Strictly Necessary: These Data Collection Tools enable you to access the
   site, provide basic functionality (like logging in or accessing content),
   secure the site, protect against fraudulent logins, and detect and prevent
   abuse or unauthorized use of your account. These are required for the
   Services to work properly, so if you disable them, parts of the site will
   break or be unavailable.
 * Functional: These Data Collection Tools remember data about your browser and
   your preferences, provide additional site functionality, customize content to
   be more relevant to you, and remember settings affecting the appearance and
   behavior of the Services (like your preferred language or volume level for
   video playback).
 * Performance: These Data Collection Tools help measure and improve the
   Services by providing usage and performance data, visit counts, traffic
   sources, or where an application was downloaded from. These tools can help us
   test different versions of Udemy to see which features or content users
   prefer and determine which email messages are opened.
 * Advertising: These Data Collection Tools are used to deliver relevant ads (on
   the site and/or other sites) based on things we know about you like your
   Usage and System Data (as detailed in Section 1), and things that the ad
   service providers know about you based on their tracking data. The ads can be
   based on your recent activity or activity over time and across other sites
   and services. To help deliver tailored advertising, we may provide these
   service providers with a hashed, anonymized version of your email address (in
   a non-human-readable form) and content that you share publicly on the
   Services.
 * Social Media: These Data Collection Tools enable social media functionality,
   like sharing content with friends and networks. These cookies may track a
   user or device across other sites and build a profile of user interests for
   targeted advertising purposes.

You can set your web browser to alert you about attempts to place cookies on
your computer, limit the types of cookies you allow, or refuse cookies
altogether. If you do, you may not be able to use some or all features of the
Services, and your experience may be different or less functional. To learn more
about managing Data Collection Tools, refer to Section 6.1 (Your Choices About
the Use of Your Data) below.


3. WHAT WE USE YOUR DATA FOR

We use your data to do things like provide our Services, communicate with you,
troubleshoot issues, secure against fraud and abuse, improve and update our
Services, analyze how people use our Services, serve personalized advertising,
and as required by law or necessary for safety and integrity. We retain your
data for as long as it is needed to serve the purposes for which it was
collected.

We use the data we collect through your use of the Services to:

 * Provide and administer the Services, including to facilitate participation in
   educational content, issue completion certificates, display customized
   content, and facilitate communication with other users (Account Data; Shared
   Content; Learning Data; System Data; Usage Data; Approximate Geographic
   Data);
 * Process payments to instructors and other third parties (Student Payment
   Data; Instructor Payment Data);
 * Process your requests and orders for educational content, products, specific
   services, information, or features (Account Data; Learning Data; Student
   Payment Data; System Data; Communications and Support);
 * Communicate with you about your account by (Account Data; Shared Content;
   Learning Data; Sweepstakes, Promotions, and Surveys; System Data;
   Communications and Support):
   * Responding to your questions and concerns;
   * Sending you administrative messages and information, including messages
     from instructors, students, and teaching assistants; notifications about
     changes to our Service; and updates to our agreements;
   * Sending you information, such as by email or text messages, about your
     progress in courses and related content, rewards programs, new services,
     new features, promotions, newsletters, and other available
     instructor-created content (which you can opt out of at any time);
   * Sending push notifications to your wireless device to provide updates and
     other relevant messages (which you can manage from the “options” or
     “settings” page of the mobile app);
 * Manage your account and account preferences and personalize your experience
   (Account Data; Learning Data; Student Payment Data; Instructor Payment Data;
   System Data, Usage Data, Cookie Data);
 * Facilitate the Services’ technical functioning, including troubleshooting and
   resolving issues, securing the Services, and preventing fraud and abuse
   (Account Data; Student Payment Data; Instructor Payment Data; Communications
   and Support; System Data; Approximate Geographic Location);
 * Verify the identity of instructors (Account Data; Instructor Payment Data);
 * Solicit feedback from users (Account Data; Communications and Support);
 * Market products, services, surveys, and promotions (Account Data; Learning
   Data; Sweepstakes, Promotions, and Surveys; Usage Data; Cookie Data);
 * Market Subscription Plans to prospective customers (Account Data; Learning
   Data; Cookie Data);
 * Learn more about you by linking your data with additional data through
   third-party data providers and/or analyzing the data with the help of
   analytics service providers (Account Data; Data About Your Accounts on Other
   Services; Usage Data; Cookie Data);
 * Identify unique users across devices (Account Data; System Data; Cookie
   Data);
 * Tailor advertisements across devices (Cookie Data);
 * Improve our Services and develop new products, services, and features (all
   data categories), including through the use of AI consistent with the
   Instructor GenAI Policy (Instructor Shared Content);
 * Analyze trends and traffic, track purchases, and track usage data (Account
   Data; Learning Data; Student Payment Data; Communications and Support; System
   Data; Usage Data; Approximate Geographic Data; Cookie Data);
 * Advertise the Services on third-party websites and applications (Account
   Data; Cookie Data);
 * As required or permitted by law (all data categories); or
 * As we, in our sole discretion, otherwise determine to be necessary to ensure
   the safety or integrity of our users, employees, third parties, the public,
   or our Services (all data categories).

We may process your inputs into the AI Assistant chatbot or other generative
artificial intelligence (GenAI) features using GenAI in order to respond to your
question or request, but we do not use your personal data to train or fine tune
GenAI models.


4. WHO WE SHARE YOUR DATA WITH

We share certain data about you with instructors, other students, companies
performing services for us, Udemy affiliates, our business partners, analytics
and data enrichment providers, your social media providers, companies helping us
run promotions and surveys, and advertising companies who help us promote our
Services. We may also share your data as needed for security, legal compliance,
or as part of a corporate restructuring. Lastly, we can share data in other ways
if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or
as otherwise described in this Privacy Policy:

 * With Your Instructors: We share data that we have about you (except your
   email address) with instructors or teaching assistants for educational
   content you access or request information about, so they can improve their
   content for you and other students. This data may include things like your
   country, browser language, operating system, device settings, the site that
   brought you to Udemy, and certain activities on Udemy, like enrolled courses
   and course review. We will not share your email address with instructors or
   teaching assistants. (Account Data; System Data; Usage Data; Approximate
   Geographic Data)
 * With Other Students and Instructors: Depending on your settings, your Shared
   Content and profile data may be publicly viewable, including to other
   students and instructors. If you ask a question to an instructor or teaching
   assistant, your information (including your name) may also be publicly
   viewable. (Account Data; Profile Data; Shared Content)
 * With Service Providers, Contractors, and Agents: We share your data with
   third-party companies who perform services on our behalf, like payment
   processing, fraud and abuse prevention, data analysis, marketing and
   advertising services (including retargeted advertising), email and hosting
   services, and customer services and support. These service providers may
   access your personal data and are required to use it solely as we direct, to
   provide our requested service. (All data categories)
 * With Udemy Affiliates: We may share your data within our corporate family of
   companies that are related by common ownership or control to enable or
   support us in providing the Services. (All data categories)
 * With Business Partners: We have agreements with other websites and platforms
   to distribute our Services and drive traffic to Udemy. Depending on your
   location, we may share your data with these trusted partners. (Account Data;
   Learning Data; Communications and Support; System Data)
 * With Credit-Granting Organizations for Continuing Education: If you take a
   course to fulfill a continuing professional education requirement, we may
   share that information upon request of the organization granting the
   continuing education credit. (Account Data; Learning Data)
 * With Analytics and Data Enrichment Services: As part of our use of
   third-party analytics tools like Google Analytics and data enrichment
   services like ZoomInfo, we share certain contact information or de-identified
   data. De-identified data means data where we’ve removed things like your name
   and email address and replaced it with a token ID. This allows these
   providers to provide analytics services or match your data with
   publicly-available database information (including contact and social
   information from other sources). We do this to communicate with you in a more
   effective and customized manner. (Account Data; System Data; Usage Data;
   Cookie Data)
 * To Power Social Media Features: The social media features in the Services
   (like the Facebook Like button) may allow the third-party social media
   provider to collect things like your IP address and which page of the
   Services you’re visiting, and to set a cookie to enable the feature. Your
   interactions with these features are governed by the third-party company’s
   privacy policy. (System Data; Usage Data; Cookie Data)
 * To Administer Promotions and Surveys: We may share your data as necessary to
   administer, market, or sponsor promotions and surveys you choose to
   participate in, as required by applicable law (like to provide a winners list
   or make required filings), or in accordance with the rules of the promotion
   or survey. (Account Data; Sweepstakes, Promotions, and Surveys)
 * For Advertising: If we decide to use an advertising-supported revenue model
   in the future, we may use and share certain System Data and Usage Data with
   third-party advertisers and networks to show general demographic and
   preference information among our users. We may also allow advertisers to
   collect System Data through Data Collection Tools (as detailed in Section
   2.1), to use this data to offer you targeted ad delivery to personalize your
   user experience (through behavioral advertising) and to undertake web
   analytics. Advertisers may also share with us the data they collect about
   you. To learn more or opt out from participating ad networks’ behavioral
   advertising, see Section 6.1 (Your Choices About the Use of Your Data) below.
   Note that if you opt out, you’ll continue to be served generic ads. (System
   Data)
 * For Security and Legal Compliance: We may disclose your data (all data
   categories) to third parties if we (in our sole discretion) have a good faith
   belief that the disclosure is:
   * Requested as part of a judicial, governmental, or legal inquiry, order, or
     proceeding;
   * Reasonably necessary as part of a valid subpoena, warrant, or other
     legally-valid request;
   * Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other
     legal agreements;
   * Required to detect, prevent, or address fraud, abuse, misuse, potential
     violations of law (or rule or regulation), or security or technical issues;
   * Reasonably necessary in our discretion to protect against imminent harm to
     the rights, property, or safety of Udemy, our users, employees, members of
     the public, or our Services;
   * We may also disclose data about you to our auditors and legal advisors in
     order to assess our disclosure obligations and rights under this Privacy
     Policy; or
   * Required or permitted by law.
 * During a Change in Control: If Udemy undergoes a business transaction like a
   merger, acquisition, corporate divestiture, or dissolution (including
   bankruptcy), or a sale of all or some of its assets, we may share, disclose,
   or transfer all of your data to the successor organization during such
   transition or in contemplation of a transition (including during due
   diligence). (All data categories)
 * After Aggregation/De-identification: We may disclose or use aggregated or
   de-identified data for any purpose.
 * With Your Permission: With your consent, we may share data to third parties
   outside the scope of this Privacy Policy. (All data categories)

If you click on any links to third-party sites, the collection, use, and
disclosure of your personal data is governed by the third-party’s privacy
policy.


5. SECURITY

We use appropriate security based on the type and sensitivity of data being
stored. As with any internet-enabled system, there is always a risk of
unauthorized access, so it’s important to protect your password and to contact
us if you suspect any unauthorized access to your account.

Udemy takes appropriate security measures to protect against unauthorized
access, alteration, disclosure, or destruction of your personal data that we
collect and store. These measures vary based on the type and sensitivity of the
data. Unfortunately, however, no system can be 100% secured, so we cannot
guarantee that communications between you and Udemy, the Services, or any
information provided to us in connection with the data we collect through the
Services will be free from unauthorized access by third parties. Your password
is an important part of our security system, and it is your responsibility to
protect it. You should not share your password with any third party, and if you
believe your password or account has been compromised, you should change it
immediately and contact our Support Team with any concerns.


6. YOUR RIGHTS

You have certain rights around the use of your data, including the ability to
opt out of promotional emails, cookies, and collection of your data by certain
third parties. You can update or terminate your account from within our
Services, and can also contact us for individual rights requests about your
personal data. Parents who believe we’ve unintentionally collected personal data
about their underage child should contact us for help deleting that information.


6.1 YOUR CHOICES ABOUT THE USE OF YOUR DATA

You can choose not to provide certain data to us, but you may not be able to use
certain features of the Services.

 * To stop receiving promotional communications from us, you can opt out by
   using the unsubscribe mechanism in the promotional communication you receive
   or by changing the email preferences in your account. Note that regardless of
   your email preference settings, we will send you transactional and
   relationship messages regarding the Services, including administrative
   confirmations, order confirmations, important updates about the Services, and
   notices about our policies.
 * If you’re located in the European Economic Area, you may opt out of certain
   Data Collection Tools by clicking the “Cookie settings“ link at the bottom of
   any page.
 * The browser or device you use may allow you to control cookies and other
   types of local data storage. To learn more about managing cookies, visit
   https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may
   also allow you to control whether location or other data is collected and
   shared.
 * To get information and control cookies used for tailored advertising from
   participating companies, see the consumer opt-out pages for the Network
   Advertising Initiative and Digital Advertising Alliance, or if you’re located
   in the European Economic Area, visit the Your Online Choices site. If you’re
   located in Japan, visit the Digital Advertising Consortium. To opt out of
   Google’s display advertising or customize Google Display Network ads, visit
   the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the
   Opt-out Link in their Cookie Policy.
 * To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to
   use your data for analytics or enrichment, see the Google Analytics Opt-out
   Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data
   claiming mechanism.
 * Apple iOS, Android OS, and Microsoft Windows each provide their own
   instructions on how to control in-app tailored advertising. For other devices
   and operating systems, you should review your privacy settings on that
   platform.

If you have any questions about your data, our use of it, or your rights,
contact us at privacy@udemy.com.


6.2 ACCESSING, UPDATING, AND DELETING YOUR PERSONAL DATA

You can access and update your personal data that Udemy collects and maintains
as follows:

 * To update data you provide directly, log into your account and update your
   account at any time.
 * To terminate your account:
   * If you are a student, visit your profile settings page and follow the steps
     detailed here.
   * If you are an instructor, follow the steps detailed here.
   * If you have any issues terminating your account, please contact our Support
     Team.
   * Please note: even after your account is terminated, some or all of your
     data may still be visible to others, including without limitation any data
     that has been (a) copied, stored, or disseminated by other users (including
     comments on content); (b) shared or disseminated by you or others
     (including in your shared content); or (c) posted to a third-party
     platform. Even after your account is terminated, we retain your data for as
     long as we have a legitimate purpose to do so (and in accordance with
     applicable law), including to assist with legal obligations, resolve
     disputes, and enforce our agreements. We may retain and disclose such data
     pursuant to this Privacy Policy after your account has been terminated.
 * To request to access, correct, or delete your personal data, please use our
   online form here. You can also submit these requests by emailing
   privacy@udemy.com or writing to us at Udemy, Attn: Privacy/Legal Team, 600
   Harrison Street, 3rd floor, San Francisco CA 94107. Please allow up to 30
   days for a response. For your protection, we may require that the request be
   sent through the email address associated with your account, and we may need
   to verify your identity before implementing your request. Please note that we
   retain certain data where we have a lawful basis to do so, including for
   mandatory record-keeping and to complete transactions.


6.3 OUR POLICY CONCERNING CHILDREN

We recognize the privacy interests of children and encourage parents and
guardians to take an active role in their children’s online activities and
interests. Individuals younger than 18 years of age, but of the required age for
consent to use online services where they live (for example, 13 in the US or 16
in Ireland), may not set up an account, but may have a parent or guardian open
an account and help them access appropriate content. Individuals younger than
the required age for consent to use online services may not use the Services. If
we learn that we’ve collected personal data from a child under those ages, we
will take reasonable steps to delete it.

Parents who believe that Udemy may have collected personal data from a child
under those ages can submit a request that it be removed to privacy@udemy.com.


7. JURISDICTION-SPECIFIC RULES

If you live in California, you have certain rights related to accessing and
deleting your data, as well as learning who we share your data with. If you live
in Australia, you have the right to make a formal complaint with the appropriate
government agency. Users outside of the United States should note that we
transfer data to the US and other areas outside of the European Economic Area.


7.1 USERS IN CALIFORNIA

Users who are California residents have certain rights under the California
Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included
in these rights are:

 * “Right to Know” — You have the right to request to know more about the
   categories and specific pieces of personal information that we have collected
   about you and access a copy of your personal information.
 * “Right to Correction” — You have the right to have inaccurate personal
   information about you corrected.
 * “Right to Deletion” — You have the right to request deletion of personal
   information that we have collected about you.
 * “Right to Non-Discrimination” — If you choose to exercise any of your rights
   under CCPA, Udemy will treat you like all other users. In other words, there
   is no penalty for exercising your rights under CCPA.
 * “Right to Opt-Out” - You have the right to opt out of the sale or sharing of
   your personal information.

CCPA has a specific definition of a “sale” and “sharing” and while Udemy does
not, in the traditional sense, sell your personal information or the personal
information of any of our users, we do use cookies that make non-personally
identifiable information available to select third-parties, including for
cross-context advertising. To opt out of such a “sale” and “sharing,” click on
the “Do Not Sell or Share My Personal Information” link at the bottom of this
page.

To exercise any of these rights under CCPA, please email privacy@udemy.com or
write to us at Udemy, Attn: Privacy/Legal Team, 600 Harrison Street, 3rd floor,
San Francisco CA 94107. CCPA allows you to designate an authorized agent to make
these requests on your behalf. For your protection, we may require that the
request be sent through the email address associated with your account, and we
may need to verify you and/or your agent’s identity before fulfilling your
request.

Additionally, for more information about the personal information we collect and
how we collect it, please see the sections above entitled “What Data We Get” and
“How We Get Data About You.”

To learn about the business and commercial purposes for which your personal
information is collected and the categories of service providers who have access
to your personal information, please see the sections above entitled “What We
Use Your Data For” and “Who We Share Your Data With.”

As a California resident, you also have the right to request certain details
about what personal information we share with third parties for those third
parties’ direct marketing purposes. To submit your request, send an email to
privacy@udemy.com with the phrase “California Shine the Light” and include your
mailing address, state of residence, and email address.

Since there is no widely accepted standard for the browser-initiated Do Not
Track signal, we do not currently recognize or respond to Do Not Track signals.


7.2 USERS IN NEVADA

Udemy does not sell its users’ personal information or personal data.
Nonetheless, Nevada residents have the right to submit a request that we do not
sell your covered personal information, which you can do by emailing
privacy@udemy.com or writing to us at Udemy, Attn: Privacy/Legal Team, 600
Harrison Street, 3rd floor, San Francisco CA 94107.


7.3 USERS IN AUSTRALIA

If you are an Australia resident and you have a complaint, you may refer it to
the office of the Australian Information Commissioner (“OAIC”). You can contact
OAIC by visiting www.oaic.gov.au; forwarding an email to enquiries@oaic.gov.au;
telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001.
You may contact our privacy team at privacy@udemy.com to make a complaint about
a breach of the Australian Privacy Principles which will be responded to within
30 days.


7.4 USERS IN THE EUROPEAN ECONOMIC AREA (“EEA”) AND UNITED KINGDOM (“UK”)

If you are located in the EEA or UK, you have the right to request access to
your data in a portable format and to request the rectification, erasure,
restriction of processing, or objection to processing of your personal data. You
may use the information in Section 6.2 to submit your request. Additionally, if
you are located in the EEA, UK, or Switzerland, you also have the right to lodge
a complaint with your supervisory authority.

Personal data is also processed outside of the UK, Switzerland, and the EEA by
our Udemy group companies, or our service providers, including to process
transactions, facilitate payments, and provide support services as described in
Section 4. We use the Controller-to-Processor Standard Contractual Clauses
adopted by the European Commission to facilitate transfers of personal data from
the EEA to third countries and have entered into data processing agreements with
our service providers and Udemy group companies to restrict and regulate their
processing of your data. By submitting your data or using our Services, you
consent to this transfer, storage, and processing by Udemy and its processors.


7.5 DATA PRIVACY FRAMEWORK (FOR EU/EEA, UK, AND SWISS DATA SUBJECTS)

Udemy, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Udemy, Inc.
has certified to the U.S. Department of Commerce that it adheres to the EU-U.S.
Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union in reliance on the
EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK
Extension to the EU-U.S. DPF. Udemy, Inc. has certified to the U.S. Department
of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any
conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more
about the Data Privacy Framework (DPF) program, and to view our certification,
please visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over Udemy Inc.’s compliance with
the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the
EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

We are committed to subject to the DPF Principles all personal data received
from the European Union, UK and Gibraltar, and Switzerland. The types of
personal data collected are described in Section 1 of this Privacy Policy. The
purposes for which we collect and use personal data are described in Section 3
of this Privacy Policy. The type of third parties to whom we disclose personal
data are described in Section 4 of this Privacy Policy. We remain responsible
for any of your personal data that is shared under the Onward Transfer Principle
with third parties for external processing on our behalf. Additionally, we may
be required to disclose personal data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements. Udemy, Inc. shall remain liable under the DPF Principles if its
agent processes personal information in a manner inconsistent with the DPF
Principles, unless Udemy, Inc. proves that it is not responsible for the event
giving rise to the damage.

Individuals have the right to access their personal data, and instructions on
doing so are provided in Section 6.2 of this Privacy Policy. Individuals may
also limit the use and disclosure of their personal data as described in Section
6.1.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. DPF, Udemy, Inc. commits to resolve DPF Principles-related complaints
about our collection and use of your personal information. EU, UK and Swiss
individuals with inquiries or complaints regarding our handling of personal data
received in reliance on EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and
the Swiss-U.S. DPF, should first contact Udemy at privacy@udemy.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. DPF, Udemy, Inc. commits to refer unresolved complaints concerning
our handling of personal data received in reliance on EU-U.S. DPF, the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, to the International
Centre for Dispute Resolution/American Arbitration Association (ICDR-AAA), an
alternative dispute resolution provider based in the United States. If you do
not receive timely acknowledgment of your DPF Principles-related complaint from
us, or if we have not addressed your DPF Principles-related complaint to your
satisfaction, please visit https://go.adr.org/dpfeufiling.html for more
information or to file a complaint. The services of ICDR-AAA are provided at no
cost to you. Under certain conditions, you may invoke binding arbitration for
complaints regarding DPF compliance not resolved by any of the other DPF
mechanisms as more particularly detailed here:
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2


7.6 USERS OUTSIDE OF THE U.S.

In order to provide the Services to you, we must transfer your data to the
United States and process it there. If you are using the Services from outside
the United States, you consent to the transfer, storage, and processing of your
data in and to the United States or other countries.


8. UPDATES & CONTACT INFO

When we make a material change to this policy, we’ll notify users via email,
in-product notice, or another mechanism required by law. Changes become
effective the day they’re posted. Please contact us via email or postal mail
with any questions, concerns, or disputes.


8.1 MODIFICATIONS TO THIS PRIVACY POLICY

From time to time, we may update this Privacy Policy. If we make any material
change to it, we will notify you via email, through a notification posted on the
Services, or as required by applicable law. We will also include a summary of
the key changes. Unless stated otherwise, modifications will become effective on
the day they are posted.

As permitted by applicable law, if you continue to use the Services after the
effective date of any change, then your access and/or use will be deemed an
acceptance of (and agreement to follow and be bound by) the revised Privacy
Policy. The revised Privacy Policy supersedes all previous Privacy Policies.


8.2 INTERPRETATION

Any capitalized terms not defined in this policy are defined as specified in
Udemy's Terms of Use. Any version of this Privacy Policy in a language other
than English is provided for convenience. If there is any conflict with a
non-English version, you agree that the English language version will control.


8.3 QUESTIONS

If you have any questions, concerns, or disputes regarding our Privacy Policy,
please feel free to contact our privacy team (including our Data Protection
Officer) at privacy@udemy.com. You can also send postal mail to us at Udemy,
Attn: Legal, 600 Harrison Street, 3rd Floor, San Francisco, CA 94107.

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