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The policy discloses that Chegg collects data revealing racial origin derived from audio, video, or pictorial information submitted by users, and uses this data for identity verification, service improvement, security, hiring-related purposes, and legal compliance; the policy states this category is not sold or shared for targeted advertising.
This analysis describes what Chegg's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that Chegg collects a sensitive data category, data revealing racial origin, from user-submitted audiovisual and pictorial content, which constitutes sensitive personal information under CCPA and may trigger heightened processing restrictions, consent requirements, or data protection impact assessment obligations under applicable state and international frameworks.
Interpretive note: Whether collection of audio, video, or pictorial data constitutes biometric processing triggering Illinois BIPA or similar statutes depends on the specific technical processing methods used, which are not described in the policy.
The updated policy expands disclosure of how personal data is collected, used, and shared across Chegg's services and regional contexts. Users in the EEA, UK, Switzerland, and the US now have access to region-specific privacy disclosures that detail additional legal rights applicable in their jurisdictions. The policy explicitly states that when users access services through an educational institution or employer, Chegg will share personal data and service usage information with that institution or employer to allow monitoring of service use. The policy also discloses that user-provided content, including audio, video, and written materials, may be used to train or fine-tune Chegg and third-party AI models. Users can review their region-specific disclosures and Busuu's supplemental privacy policy to understand additional rights and practices.
View change record →The agreement establishes that data revealing racial origin may be derived from audio, video, or pictorial content users submit to Chegg's services and may be disclosed to affiliated companies, technology service providers, security vendors, and government agencies, though the policy states it is not sold or shared for targeted advertising.
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"K. Data Revealing Racial Origin (such as audio, video, or pictorial information) a. Purposes for Collection: (1) Provide You Services (to provide you with content or other services and allow you to participate in features we offer); (2) Administrative (to verify your identity); (3) Internal Business Purposes (to improve our products or services); Security (to investigate, prevent, detect, and protect against misuse of our systems, fraud or other crime, or activities that violate our policies); (4) Hiring Related Purposes (to facilitate your job search; process your application to work with/for Chegg; prepare related governmental and internal statistics reports) ... c. Third Parties to whom the Data May Be Sold/Shared for Targeted Advertising: This category of data is not sold or shared for targeted advertising.Excerpt from Chegg's Privacy Policy
REGULATORY LANDSCAPE: Collection of data revealing racial origin constitutes processing of sensitive personal information under CCPA, which may require a limited use notice and the right to limit use and disclosure. Under GDPR for covered EU/EEA users, data revealing racial or ethnic origin is a special category of data under Article 9, requiring explicit consent or another enumerated legal basis, enforced by EU data protection authorities. The FTC Act is relevant to the extent the collection or use of this category is unfair or deceptive relative to user expectations. GOVERNANCE EXPOSURE: High. Collection of racial origin data from audiovisual content implicates biometric and sensitive data protections in multiple jurisdictions. The stated purposes include identity verification and internal product improvement, which may require explicit consent or documented legitimate interest assessments depending on jurisdiction. The breadth of technology service providers listed as recipients of this category requires review of data processing agreements. JURISDICTION FLAGS: California creates significant exposure as racial origin data is sensitive personal information under CCPA with associated opt-out and limited use rights. Illinois BIPA may be implicated if facial recognition or biometric identifiers are derived from submitted images or video, creating potential for statutory damages claims. EU/EEA users are subject to GDPR Article 9 special category protections. Texas and Washington also have biometric privacy statutes that may apply depending on how the audiovisual data is processed. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with technology service providers and affiliated companies receiving this category of data should specify purpose limitations consistent with the stated uses in the policy. If any vendor performs automated analysis of audiovisual content to derive racial origin indicators, additional contractual protections and legal basis documentation may be required, particularly for Illinois BIPA and GDPR Article 9 compliance. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the stated purposes for collecting racial origin data, including identity verification and product improvement, are supported by adequate legal bases in each jurisdiction where users are located, audit whether a CCPA limited use mechanism is implemented for this sensitive category, review whether any automated processing of audiovisual content for identity verification constitutes biometric processing under state biometric privacy laws, and conduct a data protection impact assessment for EU/EEA users if not already completed.
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This provision establishes that Chegg collects a sensitive data category, data revealing racial origin, from user-submitted audiovisual and pictorial content, which constitutes sensitive personal information under CCPA and may trigger heightened processing restrictions, consent requirements, or data protection impact assessment obligations under applicable state and international frameworks.
The agreement establishes that data revealing racial origin may be derived from audio, video, or pictorial content users submit to Chegg's services and may be disclosed to affiliated companies, technology service providers, security vendors, and government agencies, though the policy states it is not sold or shared for targeted advertising.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Chegg.