Privacy Policy

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Last Modified: October 27, 2022

edX Boot Camps (Canada) ULC (edX Boot Camps) is an affiliate of edX LLC (edX).  edX Boot Camps and edX are both wholly owned and operated by 2U, Inc.  This privacy policy applies only to personal information collected by edX Boot Camps to provide this boot camp.  Please visit the edX Privacy Policy and edX Terms of Use, for more information about data practices that apply to courses and programs offered by edX on edx.org.

Carleton University (the “School”), in association with edX Boot Camps (Canada) ULC (as owned and operated by 2U, Inc.) with its registered address at 2200 HSBC Building, 885 West Georgia Street, Vancouver BC V6C 3E8 (“edX Boot Camps,” “we,” or “us”), provides this boot camp (the “Program”). This privacy policy (the “Privacy Policy”) describes how edX Boot Camps collects, uses, and discloses information from and about you when you visit and use https://bootcamp.carleton.ca/ (the “Website”), as well as your ability to control certain uses of that information. It also describes certain data protection rights which apply, subject to applicable law, including a right to object to some of the processing which edX Boot Camps carries out. More information about your rights, and how to exercise them, is set out in Accessing and Managing Your Personal Information below. If you are a Canadian resident, please see the section below “Notice for Canadian Residents” for information relating to your rights relating to your personal information. If you are a California resident, please see our Notice to California Consumers for information regarding rights of California residents.

edX Boot Camps 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 Boot Camp Terms, and to edX Boot Camps‘s collection, use, and disclosure of your information in accordance with this Privacy Policy, where such agreement is permitted by applicable law. If you choose to apply or enroll in the Program, use of your personal information, including your education records, if applicable, will be governed by the Learning Management System Privacy Policy.

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

edX Boot Camps 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 edX Boot Camps-powered Programs, or otherwise contact us or provide information to us through the Website. 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:

Information Automatically Collected

When you visit the Website or interact with emails 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 Website, such as the date and time of your visit, the information you searched to find the Website, your activity on the Website, and your clicks on our ads. “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 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 Website. 

Please see edX Boot Camps’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 Website. 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 (as defined below), your employer, companies to which you indicate that you would like to learn more about the Program, edX Boot Camps‘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 Website and from Other Sources to help us tailor our communications to you and to improve the Website.

Failure to Provide Personal Information

Failure to provide certain information may make it difficult or impossible for you to access some services through the Website. 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.

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 16.

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 described above. For more details on the balancing tests 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, edX Boot Camps may collect and process your personal information at the direction of the School, for instance processing certain of your application materials or applicable loan documentation from the School. If you have any questions about your School’s collection, use or disclosure of your personal information, please contact your School and review their privacy policy.

Use of De-identified, Aggregate or Anonymized Information

We use de-identified, aggregate or anonymized information to help us analyze the use of the Website. 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 at our discretion.

How We Disclose Your Information

edX Boot Camps 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 Program, track your participation in the Program, and/or fulfill our contracted responsibilities to the School. Once we share your personal information with the School, edX Boot Camps 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 or given your consent, we share your information with 2U, Inc, and 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 edX Boot Camps, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, edX Boot Camps 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 or Sponsor: We share your information with your employer or sponsor, in the event that such third party is paying for your Program. Information disclosed in this case shall include Program performance information, unless otherwise expressly agreed in writing with edX Boot Camps.
  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 edX Boot Camps.
  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 Website, servers, network systems, and databases. We also disclose your information, as necessary, if we believe that there has been a violation of our Boot Camp Terms (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: edX Boot Camps 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 Kingdom, 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 or a Service Provider’s 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 any 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 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 Website or otherwise. If you choose not to provide this personal information or request that edX Boot Camps 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 Website or advertised about the Program. 

If you wish to access or delete your information as described in this section, please fill out edX Boot Camps‘s Data Request Form.  If you believe your rights regarding your personal information have been infringed upon, please contact us privacy@trilogyed.com. For individuals located in the United Kingdom, EEA or Switzerland who have unresolved concerns, you also have a right to lodge a complaint with your applicable Data Protection Authority.


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 School’s FERPA office. Any FERPA-protected information will be processed by edX Boot Camps at the direction of the School and will not be used for targeted advertising.

NOTICE FOR CANADIAN RESIDENTS

If you are a Canadian resident, this section applies to you. 

Consent: By submitting personal information to edX Boot Camps, or our service providers and agents, you consent to the collection use, disclosure, and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information time by contacting edX Boot Camps at privacy@trilogyed.com. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that edX Boot Camps may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you.

Retention of Personal Information: The personal information that you provide will be retained by edX Boot Camps in accordance with applicable laws. However, we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for the purposes for which it was collected.

Access and Correction: edX Boot Camps will take reasonable steps to ensure the personal information we hold is accurate, complete and up-to-date. Upon your written request, and subject to certain exceptions provided by law, edX Boot Camps will inform you of the existence, use, and disclosure of your personal information and give you access to that information. edX Boot Camps may charge a minimal fee for providing such access to you. If you believe that the personal information that edX Boot Camps holds about you is not accurate or complete, you may write to the edX Boot Camps at privacy@trilogyed.com. If you are able to establish that the information is not accurate or complete, edX Boot Camps will take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. In order to facilitate a request to correct or update information, edX Boot Camps may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by edX Boot Camps.

Interest-Based Advertising: To opt-out of interest-based advertising, and to find information about how to block or limit cookies, visit AdChoices, the Canadian self-regulatory program for online interest-based advertising, administered by the Digital Advertising Alliance of Canada (“DAAC”).

Canada’s Anti Spam Law (“CASL”)

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.

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 (i.e., residents of California) that edX Boot Camps collects and discloses for a business purpose. 

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

In some cases, we share Identifiers and Usage Data with business partners in order to deliver ads that are more relevant to you and to measure and report on the effectiveness of our advertising campaigns. Under the CCPA, some of this data sharing may be broadly considered a “sale” of information, even though these activities do not fit what most people would understand “sale” to mean.  Except for this type of sharing, we do not sell your information.  To opt out of the sale of your personal information, please visit edX Boot Camps‘s Do Not Sell My Information page.

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 edX Boot Camps‘s Data Request Form or by contacting us at 1-888-213-3391.  To opt out of the sale of your personal information, please visit edX Boot Camps‘s Do Not Sell My Information page.

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. We do not discriminate if you exercise your rights under the CCPA.

 

California’s Shine the Light Law. If you are a California resident and do not want edX Boot Camps to disclose your information to third parties (including to affiliates within the 2U family of companies) for their direct market marketing purposes, you may opt out here.

Public Forums; Publicly Available Content

Any information you may disclose through the Website 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, including your classmates and learning facilitators. Please exercise caution when disclosing personal information in these public areas. If you do not want edX Boot Camps to store metadata associated with your content, please remove the metadata before uploading your content. 

Third-Party Content 

The Website may also offer you the ability to interact with content provided by third parties not affiliated with edX Boot Camps (“Third-Party Content”). Third-Party Content linked to or embedded on this Website 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.

Questions or Concerns About this Privacy Policy 

You may direct any questions or concerns regarding this Privacy Policy to us at privacy@trilogyed.com. You can also contact our EU representative (identified below). 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 Website or by otherwise notifying you.

You also have the right to file a complaint with the data protection regulator in the country where our “data controller” is located, where our EU representative is located (if you live in the EU), or the country where you live (e.g., if you live in Europe, the European Data Protection Authority where you live, or if you live in South Africa, the information regulator). A list of edX Boot Camps data controllers can be found here

If you reside in the EU, you can contact our EU representative at DataRep, 12 Northbrook Road, Dublin, D06 E8W5, Ireland, datarequest@datarep.com. If you reside in the UK, you can contact our UK representative at 2U Group (UK) Ltd, c/o Skadden, Arps, Slate, Meagher & Flom (UK) LLP, 40 Bank Street Canary Wharf, London, United Kingdom, E14 5DS, +44 20 3457 5774.

To make a request to delete or access personal data, or for more information about the personal data edX Boot Camps has about you, use edX Boot Camps‘s Data Request Form.

View Carleton University‘s Privacy Policy

View the previous version of this Privacy Policy