Thank you for choosing K360. At K360 ("K360", "we", "us"), we prioritize your privacy and aim to provide transparency regarding how we collect, utilize, and share your data. This Privacy Policy outlines our data collection practices and elucidates your rights concerning your personal data. This Policy applies to your interactions with K360 websites, mobile applications, APIs, and associated services ("Services"). It also extends to prospective customers of our business and enterprise offerings. By utilizing our Services, you consent to the terms outlined in this Privacy Policy. If you do not agree with any aspect of this Policy or any other agreement governing your usage of the Services, please refrain from using them.

What Data We Obtain

We acquire certain data directly from you, such as information you input yourself, details regarding your content consumption, and data from third-party platforms connected with K360. Additionally, we automatically collect some data, including information about your device and your interactions with our Services.

Data You Provide to Us

The data we collect from or about you may vary depending on how you use our Services. Here are some examples to illustrate the types of data we collect: When you create an account and utilize our Services, either directly or through a third-party platform, we gather any data you provide, including:

Obtaining Data from Third Parties

For K360 Business enterprises or corporate prospects, aside from the information you provide directly, we may also gather specific business contact details from third-party commercial sources.

Acquiring Your Data

We utilize tools such as cookies, web beacons, and similar tracking technologies to collect the aforementioned data. Some of these tools provide you with the option to opt out of data collection.

Cookies and Data Collection Tools

Cookies, which are small text files stored by your browser, are employed to gather, store, and exchange data about your browsing activities across various websites, including K360. They enable us to retain information about your visits to K360, such as your preferred language, thereby enhancing site usability. K360, along with service providers acting on our behalf (such as Google Analytics and third-party advertisers), utilizes server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (collectively referred to as "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) during your usage of the Services. In certain cases, we correlate data obtained through these Data Collection Tools with other data collected as described in this Privacy Policy.

Purpose of Data Collection Tools

K360 employs various types of Data Collection Tools for the following purposes:

1. Strictly Necessary: These tools enable site access, provide essential functionality (like logging in or accessing content), secure the site, prevent fraudulent logins, and detect and prevent abuse or unauthorized use of your account. Disabling them may cause parts of the site to break or become unavailable.


2. Functional: These tools retain data about your browser and preferences, offer additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (such as your preferred language or video playback volume).


3. Performance: These tools assist in measuring and enhancing the Services by providing usage and performance data, visit counts, traffic sources, or application download sources. They aid in testing different versions of K360 to identify user preferences regarding features or content and determine which email messages are opened.


4. Advertising: These tools deliver relevant ads (on the site and/or other sites) based on known information about you, such as your Usage and System Data (as detailed in Section 1), and data obtained by ad service providers through tracking activities. To deliver personalized advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and publicly shared content on the Services.


5. Social Media: These tools enable social media functionality, allowing content sharing with friends and networks. They may track user or device activity across other sites to create user interest profiles for targeted advertising purposes.

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:

1. 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)


2. Process payments to instructors and other third parties (Student Payment Data; Instructor Payment Data);


3. 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);


4. Communicate with you about your account by (Account Data; Shared Content; Learning Data; Sweepstakes, Promotions, and Surveys; System Data; Communications and Support)


5. 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);


6. 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);


7. Verify the identity of instructors (Account Data; Instructor Payment Data);


8. Solicit feedback from users (Account Data; Communications and Support);


9. Market products, services, surveys, and promotions (Account Data; Learning Data; Sweepstakes, Promotions, and Surveys; Usage Data; Cookie Data);


10. Market Subscription Plans to prospective customers (Account Data; Learning Data; Cookie Data);


11. 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);


12. Identify unique users across devices (Account Data; System Data; Cookie Data);


13. Tailor advertisements across devices (Cookie Data);


14. Improve our Services and develop new products, services, and features (all data categories);


15. 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);


16. Advertise the Services on third-party websites and applications (Account Data; Cookie Data);


17. As required or permitted by law (all data categories); or


18. 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).

Who We Share Your Data With

We disclose certain information about you to instructors, fellow students, service providers, K360 affiliates, business partners, analytics and data enrichment providers, social media platforms, promotional and survey partners, and advertising agencies aiding in the promotion of our Services. Additionally, we may share your data for security reasons, legal compliance, or during corporate reorganization. Furthermore, we may share aggregated or de-identified data or with your explicit consent. We may share your data with third parties in the following situations or as further outlined in this Privacy Policy:

1. 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)


2. 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)


3. 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)


4. With K360 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)


5. 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)


6. 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)


7. 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)


8. 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)


9. 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)


10. 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, 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.


11. 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 K360, 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.


12. During a Change in Control: If K360 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)


13. After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.


14. With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy. (All data categories)

Security

We implement appropriate security measures tailored to the type and sensitivity of the data stored. While we strive to safeguard your information, it's crucial to protect your password and promptly notify us if you suspect any unauthorized access to your account. K360 employs security protocols to prevent unauthorized access, alteration, disclosure, or destruction of the personal data we collect and retain. These protocols are customized based on the nature and confidentiality of the data. However, it's important to note that no system can guarantee absolute security. Therefore, we cannot ensure that communications between you and K360, the Services, or any data provided to us will be immune to unauthorized access by third parties. Your password plays a vital role in our security framework, and it's imperative that you keep it confidential. Avoid sharing your password with any third party, and if you suspect compromise of your password or account, take immediate action to change it and notify our Support Team of any concerns.

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.

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.

1. 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.


2. 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.

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 K360 may have collected personal data from a child under those ages can submit a request that it be removed.

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.

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.