Privacy Policy

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Last Updated: May 5, 2025

Thank you for your interest in the Hawai'i Pacific University ’s (the “School”) Master of Science in Data Science online programs (the “Program”). This privacy notice (the “Privacy Notice”) describes how the School’s technology partner, 2U, LLC and its affiliates and subsidiaries (“2U,” “we,” or “us”) collect, use, disclose and process the personal information we collect through websites, products, services, and applications that reference this Privacy Notice (together “the Services”). This notice also provides required disclosures under applicable law (see Additional Legal Disclosures section below) and serves as 2U’s Notice at Collection under the California Privacy Rights Act.

2U partners with universities and institutions (each, an “Education Institution”) to provide educational programs (each, a “Program”). However, when 2U collects and uses your personal information to process your application for a Program, or to provide a Program, we do so on behalf of the Education Institution; this collection and use of your personal information, including your education records, if applicable, will be governed by the privacy policies shown on the application website and Learning Management System, respectively.

The School’s online programs (the “Programs”) are as follows:

  • Master of Science in Data Science
  • Master of Science in Cybersecurity
  • Master of Education in Educational Leadership
  • Master of Social Work

Quick Guide to Contents

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  • Information You Provide

    2U collects and processes personal information about you, such as your name, address, e-mail address, telephone number, and the content of any communications that we exchange when you interact with the Services, including when you:

    • submit a webform requesting information about 2U-powered programs;
    • contact us or provide information to us through this website, as well as associated websites and applications that reference this Privacy Notice (together, the “Website”);
    • indicate an interest in a Program or form an enterprise partnership with 2U (you may unsubscribe from promotional emails by clicking “unsubscribe” on the emails you receive from us);
    • create an account;
    • attend a webinar; 
    • register or apply for a Program, either directly with us, through your employer, or through some other means;
    • make a payment;
    • participate in our surveys, promotions, and competitions;
    • sign up for a newsletter;
    • communicate with us, for example by submitting queries regarding the Services or a Program; and 
    • use the Services. 

    In some cases, we also require your personal information in order to perform a contract or to comply with a legal obligation. 

    Failure to provide certain information may make it difficult or impossible for you to access some aspects of the Services. 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 a Program.

    Information we collect automatically

    When you interact with the Services, including our emails and ads, we use cookies and other types of digital trackers to store your preferences, enable you to sign in, provide personalized content and ads, combat fraud and analyze how our Services perform. These cookies collect information about:

    • your device and browser, including internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information; and
    • your interactions with our Services, including the date and time of your visit, your activity on the Services, and your clicks on our ads and emails.

    Information Collected from Other Sources

    We combine personal information we receive from you with information from other sources, including: 

    • the Education Institution providing your Program, 
    • your employer or potential employer, 
    • companies to which you indicate that you would like to learn more about the Program, 
    • companies that are our partners, 
    • companies to which you’ve provided your information for professional or continuing education opportunities, 
    • data providers that provide us with details about sales contacts of our prospective and existing business customers (e.g., your job role, the size of your employer, etc.), and 
    • 2U, LLC’s affiliated companies.

  • We process personal information and aggregated or anonymized information derived from your personal information for the following purposes:

    • To fulfill a contract or take steps linked to a contract, including:
      • providing our Services. To do this, we use (i) information you provide when you interact with the Services (e.g., in order to provide you with information about a Program or another Service, we use the personal information you provide when you request information about that Program or Service), (ii) information collected through cookies and digital trackers to the extent strictly necessary to provide our Services, and (iii) information collected from other sources (e.g., if you have provided information to a company indicating you wish to learn more about a Program or another Service, we will use that information to inform you about such Program or Service);
      • taking payments. To do this, we use your name, address, and payment details;
      • communicating with you. To do this, we use your name, e-mail address, telephone number, and the content of any communications that we exchange.
    • To provide the Services, in accordance with our legitimate interests in marketing our business, ensuring that we conduct our business in line with our objectives, improving and developing our products and services, and keeping our records accurate and up to date. Providing our Services is also in the interests of Education Institutions and others that we partner with, and in the interests of individuals in obtaining access to education. This includes: 
      • providing products and services you have requested and responding to any comments or complaints you may send us. To do this, we use the information you provide when you interact with the Services, including the content of any communications that we exchange;
      • targeting advertising to you and individuals with similar interests or characteristics through services offered by third parties. We use tools made available by third-party advertising providers (e.g., Google, Microsoft, Meta, and LinkedIn) to select groups of individuals that use those third parties’ services to target relevant ads to those individuals on those services; 
      • developing new products or services or conducting analyses to enhance current products and services. To do this, we use information you provide when you interact with the Services (e.g., your location, to understand where our Services are particularly popular, information about Programs in which you have expressed an interest, information you provide through surveys); and information collected from other sources (e.g., to track which of our partners refer new users to us);
      • reviewing the usage and operations of the Website and analyzing and improving the Website. To do this, we use any feedback you provide about the Website (directly or through others); 
      • contacting you for legitimate business purposes. To do this, we use your name, e-mail address, telephone number and the content of any communications that we exchange; 
      • using personal information to invite you to take part in market research. To do this, we use your name and contact details, and your participation in the research is entirely voluntary;
      • in certain instances, where consent is not required by applicable law, to send you direct marketing messages (e.g., emails, SMS messages, telephone calls, and postal mail). These messages may relate to our Services, and those provided by 2U, LLC and its affiliates. To do this, we use your name, e-mail address, telephone number, postal address, and information about the Program(s) in which you have expressed an interest; 
      • protecting the security and functionality of the Website. To do this, we use information you have provided to us (e.g., user reviews), information we collect automatically through cookies and other digital trackers (e.g., about the pages you visit and your interactions with them), and information collected from other sources (e.g., complaints about your actions on the Services); and 
      • through our use of AI systems. We use AI Systems in phone calls, web interactions, chat bots and as may otherwise be notified to you when in use. When we use AI Systems to interact with you, we provide a prominent notice to indicate our use of AI systems.
    • Where you give us consent. This includes: 
      • where consent is required by applicable law, sending you direct marketing messages (e.g., emails, SMS messages, telephone calls, and postal mail). These messages may relate to our Services, and those provided by 2U, LLC and its affiliates. To do this, we use your name, e-mail address, telephone number, postal address, and information about the Program(s) in which you have expressed an interest. 
      • where consent is required by applicable law, targeting advertising to you and individuals with similar interests or characteristics through services offered by third parties. To do this, we use information collected through cookies and digital trackers (e.g., device identifiers, and information about pages you visited on our website). We use this information to target ads on social media sites, search engines, and other websites.
      • developing new products or services or conducting analyses to enhance current products and services. To do this, we use information collected through cookies and digital trackers (e.g., information about how users use our Website, in order to assist with error management, and to store preferences). 
      • reviewing the usage and operations of the Website and analyzing and improving the Website. To do this, we use information collected through cookies and digital trackers (e.g., information about error reports, or information about pages that users dwell on for a long time, which suggests they are confusing). 
      • personalizing your experience with the Website and helping us to better respond to your individual needs. To do this, we use information you provide us about your preferences (e.g., your language preferences), and information collected through cookies and digital trackers (e.g., to track usage of our website, assist with error management, and storing preferences);
      • verifying your identity. To do this, we use your name, identification document, country and a photograph of your face. If you do not consent to provide this information, we may not be able to provide you the requested Service; and
      • on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.
    • To comply with legal obligations, including: 
      • responding to requests by government or law enforcement authorities. The categories of data used for these purposes will depend on the request; and
      • managing legal claims, and ensuring compliance with applicable law and our policies. The categories of data used for these purposes will depend on the nature of the claim or applicable law or policy.
    • At the direction of your Education Institution, where applicable. 

  • 2U shares your information with other entities or individuals in the following circumstances: 

    1. Education Institutions: Subject to our contracts with Education Institutions, we share the information you provide to us with the relevant Education Institution that provides your Program to fulfill our contracted responsibilities to them. Once we share your personal information with the Education Institution, 2U does not maintain control over the Education Institution’s use of this information. We also share de-identified, aggregate, pseudonymous, or anonymous information with the Education Institution for their own research and analytics purposes. The Education Institution’s use of your information is subject to its privacy policy.
    2. 2U, LLC. and its affiliates: Where you have expressed interest or given your consent, we share your information with 2U, LLC’s affiliated companies to provide you with information about other educational programs.
    3. Service Providers: We share your information with third parties that provide services on our behalf, including providers of website hosting and maintenance, marketing, courier, certification, business operations, payment processing, and ID verification services (“Service Providers”). Where we share personal information with Service Providers, we do so pursuant to a contract with provisions ensuring your personal information is handled in accordance with this Privacy Notice and applicable law. These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to 2U under that contract, and they are prohibited from using or sharing your information for any other purposes. 
    4. Advertising Networks: Where permitted by law, 2U discloses limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences. This allows 2U to fulfil its legitimate business interests in providing relevant advertising, as described above. You can object to our disclosure of this information by refusing to give consent to our use of advertising cookies, through our “Your Privacy Choices” tool linked in the footer of our Websites or by submitting a request via 2U’s Data Request Form Even if you opt-out, you may still receive advertisements from 2U but they will not be personalized using cookies. 
    5. Your Employer or Sponsor or their Designee: We share personal information with your employer or sponsor, or someone designated by them, in the event that such third party is paying for your Program. This allows us to fulfill our contractual obligations to your employer, sponsor, or their designee. Information disclosed in this case shall include Program performance information, unless otherwise expressly agreed in writing with 2U.
    6. Potential Employers: Where you choose to work with our career services team, we will share your information with potential employers. This allows us to provide the service you have requested. 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 2U. 
    7. Legal Matters; Safety: We will disclose your information to third parties if required to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; to enforce our legal rights, or otherwise as required by law. We will also disclose your information, as necessary, if we believe that there has been a violation of our Terms of Use (including investigation of potential violations thereof), any other legal document or contract related to the Website, or the rights of any third party.
    8. Fraud; Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
    9. Notice / Consent: We share information with third parties when we have your consent or when we have explicitly notified you about this sharing when we collect the relevant personal information.
    10. Sale or Transfer of Business or Assets: 2U 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 Notice. Using your data in this way allows us to fulfill the purposes required by law. 
    11. International Transfers: We may transfer personal information from your location to other countries where our employees and/or servers are located, including, as applicable, Australia, Canada, the European Economic Area, Mexico, South Africa, the United Kingdom, and the United States. Where we transfer your personal information outside of the country where you are located, we put safeguards in place to protect that information. 
    12. In particular, where we transfer personal data from the EEA or the UK, we transfer it to countries that are deemed to provide an adequate level of protection by the European Commission (i.e., Canada, the United Kingdom, the EEA, and the United States (to the extent the recipient is certified to the Data Privacy Framework). Where we transfer data from the EEA or the UK to other countries (including to the United States where the recipient is not certified to the Data Privacy Framework), we use approved contractual mechanisms to do so. You can request a copy of the relevant mechanism by contacting us at privacy@2u.com.

  • We design our products with 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 Services, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. Even though we do our best to protect your information, the transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information.

  • We retain your personal information for as long as we have a relationship with you. We also may retain your personal information for a longer period of time which enables us to: 

    • maintain business records for analysis and/or audit purposes; 
    • comply with record retention requirements under the law;
    • defend or bring any existing or potential legal claims;
    • address any complaints regarding the services;
    • enforce our commercial agreements; and
    • support our legitimate interests, as described in this Privacy Notice.

  • 2U provides you various options to exercise your privacy choices and rights:

    • If you have created a profile or are enrolled in a Program, you may access and update certain personal information through your user profile. 
    • If you consented to receive marketing communications from us, you may opt out of such communications through the unsubscribe link included in such communications.
    • If you want to withdraw your consent to our use of cookies that collect your information automatically for the purposes outlined above, you can do so through our Your Privacy Choices tool linked in the footer of our Websites.
    • If you want to opt out of our use of your personal information to target ads on third-party platforms like search engines and social media sites, you can use the opt-out tools that those platforms make available.
    • If you want to withdraw your consent to our sharing of your personal information through our use of third-party advertising cookies, you can do so through our Your Privacy Choices tool linked in the footer of our websites. 
    • If you wish to exercise your privacy rights, including rights to access, correct, amend, restrict, or delete your personal information, or object to the processing of your personal information, please fill out 2U’s Data Request Form.  
    • If you believe your rights regarding your personal information have been infringed upon, please contact us at privacy@2u.com. 
    • Individuals in certain jurisdictions – including the European Economic Area, Brazil, the People’s Republic of China, South Africa, Switzerland, or the United Kingdom – have the right to lodge a complaint with the data protection authority in the country where they live.
    • If you reside in the EU, you can contact our EU representative at DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland, privacy@2u.com. If you reside in the UK, you can contact our UK representative at 2U Group (UK) LTD, ℅ Skadden, Arps, Slate, Meagher & Flom (UK) LLP, 22 Bishopsgate, London, United Kingdom, EC2N 4BQ, +44 20 3457 5774, privacy@2u.com. A list of 2U data controllers can be found here. The relevant data controller will be charged with making decisions regarding the purposes and methods of processing of data under the terms of this Privacy Notice.

  • 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, in accordance with applicable law and our confidentiality obligations 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 Education Institution’s FERPA office. Any FERPA-protected information will be processed by 2U at the direction of the Education Institution and will not be used for targeted advertising.

    Children’s Privacy

    We do not direct the Website to, nor do we knowingly collect any personal information via the Website from, children under the age of 16. If you learn that a child has provided us with personal information in violation of this Privacy Notice, you may notify us at privacy@2u.com.

    Public Forums; Publicly Available Content

    Any information you may disclose through the Services on message boards, in chat rooms, or on other public areas, such as on webinars that you may attend about a 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 2U to store metadata associated with your content, please remove the metadata before uploading your content.

    Third-Party Content, Links, and Plug-Ins

    The Services may also offer you the ability to interact with content provided by third parties not affiliated with 2U (“Third-Party Content”). Third-Party Content linked to or embedded within the Services is governed by the privacy policies of those third parties. Your use of Third-Party Content is subject to each such third party’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 NoticeYou may direct any questions or concerns regarding this Privacy Notice to us at privacy@2u.com. You may also write to us at ATTN: Privacy, 2U, LLC 2345 Crystal Drive, Suite 1100,
    Arlington, VA 22202. We review this Privacy Notice from time to time and reserve the right to make changes to this Privacy Notice at any time. If we make material changes, we will give notice via the Services or by otherwise notifying you.

  • CCPA. As required by the California Consumer Privacy Act (“CCPA”), below are the categories of personal information about California consumers that we collect and disclose to provide our Services and operate our business:

    • Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
    • Commercial Information, including records of products and services purchased and purchasing history.
    • Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, or medical information relevant to your participation in the Program.
    • Usage Data, including internet or other electronic network activity information, such as information about how you interact with our services or advertisements.
    • Audio, electronic, visual, thermal, olfactory or similar information, including voice recordings when you call us. 
    • Biometric Information, including facial recognition used for identity verification, where required by the Education Institution and/or remote proctoring.
    • Employment History, including professional or employment-related information.
    • Education Information, including information about education history or background.
    • Protected Classifications, characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability and citizenship status.
    • Inferences drawn from any of the information identified above reflecting your preferences and characteristics.

    The categories of sources of personal information we collect are described in the section Collection of Information above.

    The Purposes for collecting personal information are described in the section How We Use Your Information above. 

    We disclose the categories of personal information identified above in the section How We Disclose Your Information above.

    2U discloses pseudonymized device and browser information and information about your interactions with the Services to advertising companies that we contract with to deliver personalized ads and measure the effectiveness of our advertising campaigns. To the extent these disclosures are considered “selling” or “sharing” under California law, 2U provides you the ability to opt out of these disclosures through the “Your Privacy Choices” link in the footer of our Websites.

    2U will retain your Personal Information as identified above in the section Data Retention.

    California law gives California consumers the right to make the following requests:

    • The right to opt-out of the sale or sharing of your personal information. 
    • The right to request a copy of the personal information that we have collected about you in the prior 12 months.  
    • The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
    • The right to correct inaccurate Personal Information that we maintain about you.
    • The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.

    You can submit a copy, deletion, correction or right-to-know request online by filling out 2U’s Data Request Form or by contacting us at 1-888-213-3874.  

    You may authorize another person (your “authorized agent”) to submit a request on your behalf through the methods described above. Your authorized agent should submit proof that you gave the agent signed permission to submit the request. We may still require you to directly verify your identity and directly confirm that you have provided the authorized agent permission to submit the request.

    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. 2U does not use or disclose your sensitive personal information for purposes other than those set forth in the CCPA.
    California’s Shine the Light Law. If you are a California resident and do not want 2U to disclose your information to third parties (including to affiliates of 2U, LLC. or Education Institutions) for their direct marketing purposes, you may opt out here.