Last Modified: March 7, 2018

Thank you for your interest in The University of Denver’s Daniels College of Business (the “School”) Master of Business Administration online program (the “Program”). This privacy policy (the “Privacy Policy”) describes how 2U, Inc. (“2U,” “we,” or “us”) collects, uses, and discloses information from and about you when you visit and use onlinemba.du.edu (the “Website”), as well as your ability to control certain uses of that information. 2U respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. By accessing or otherwise using the Website, you agree to the terms and conditions of this Privacy Policy, which is incorporated into the Terms of Use, and to our collection, use, and disclosure of your information in accordance with this Privacy Policy.

2U collects information that you voluntarily submit to us, including, without limitation, when you submit a form requesting information about the Program and/or about other programs offered at other schools, provide information to us through the Website, or otherwise contact us. The information we collect may include your name, address, e-mail address, telephone number, prior educational background information (e.g., GPA range, name(s) of prior institution(s) attended, or prior degree(s) earned), and the content of any communications that we exchange.

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

We also may collect information about your use of the Website, including the times and dates you access the Website; the areas or pages of the Website that you visit; the amount of time you spend using the Website; the number of times you return to the Website; and whether you open, forward, or click-through emails.

You may adjust your browser or operating system settings to limit this tracking or to decline Cookies. If you choose to limit tracking through or decline Cookies, however, you may be unable to access certain areas of the Website. Check the “Help” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. You can learn more about the use of Cookies or other tracking or retargeting technologies and your choices regarding the use of information collected this way by certain Service Providers (as defined below), at the National Advertising Initiative. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

We may collect or receive information about you from other sources with which you interact (e.g., Facebook), companies that are our partners, or other third parties.

We may combine the information we receive from and about you to help us tailor our communications to you and to improve the Website.

2U may use the information that we collect from and about you in order to:

We may also use the information that we collect from and about you as described to you at the point of collection or otherwise for purposes which you expressly permit us to use the information. In addition, outside of our capacity as a service provider to the School, 2U may use the information we collect from and about you to provide you with information about online programs we think may be of interest to you. Finally, we may use de-identified information about you in an aggregated or anonymized manner to help us analyze the use of the Website. This Privacy Policy does not limit our use or disclosure of de-identified information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties in our discretion.

2U may share your information with other entities or individuals outside of 2U in the following limited circumstances: (1) with your consent; (2) to our Service Providers (as defined in Section 4 of this Privacy Policy), if the disclosure will enable them to perform a business, professional, or technical support function for us; (3) to satisfy any applicable law, regulation, legal process, or enforceable governmental request; (4) as necessary, to enforce the Terms of Use, including investigation of potential violations thereof; (5) to detect, prevent, or otherwise address fraud, security, or technical issues; (6) to protect against imminent harm to the rights, property, or safety of 2U, Website users, or other third party or parties, as required or permitted by law; (7) to our select partners and affiliates that we believe may have offers of interest to you; and (8) as described to you at the point of collection.

2U may also share de-identified information in an aggregated or anonymized manner with third parties for their marketing or analytics uses. For example, we provide Google Analytics with de-identified data so that they may provide us with a better understanding of visitors’ interactions with the Website, including how a visitor found the Website, actions a visitor takes while accessing the Website, or sites to which a visitor navigates after leaving the Website. Learn more about Google Analytics’ use of de-identified data.

2U may sell or purchase assets, such as your information, during the normal course of our business. For example, if another entity acquires us or any of our assets, information we collected about you up to that point 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 any such sale or transfer occur and result in a transfer of your information, 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.

For California Residents: If you do not want 2U to disclose your information to third parties (including

2U contracts with third parties to perform functions related to the Website (“Service Providers”). We only provide these Service Providers access to your information to the extent necessary to process your information and/or provide services to 2U. We do not permit Service Providers to use or share your information for other purposes.

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 Website, 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 circumvention of any privacy settings or security measures or unauthorized access to your information.

We may link to or offer some of our services in connection with third party websites or applications, which may have different privacy practices. We are not responsible for the practices of such websites or applications, and we encourage you to read and fully understand their privacy policies.

We do not direct the Website to, nor do we knowingly collect any personal information from, children under 13.

We make every effort to provide you with the ability to request that we correct or delete any information we store about you. You may make such a request by emailing us at privacy@2U.com.

2U may revise this Privacy Policy at any time and without prior notice. When we do, we will post the change(s) on the Website. In the event that we make any material change(s) to this Privacy Policy, we will make commercially reasonable attempts to notify you. We recommend that you periodically review this Privacy Policy for any updates and/or changes. Your continued use of the Website after we make changes to this Privacy Policy shall be considered your acceptance of those changes.

You may direct any questions or concerns regarding this Privacy Policy, or the practices described herein, to us at Compliance Department/Privacy, 7900 Harkins Road, Lanham, MD 20706 or privacy@2U.com.

View the previous version of this Privacy Policy.