The policy states that Coursera uses third-party advertising and analytics technologies that collect device identifiers, browsing activity, and interaction data across Coursera's services and potentially other websites via cookies and similar tracking tools.
This analysis describes what Coursera'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 authorizes the use of cross-site tracking technologies and sharing of behavioral data with advertising and analytics partners, which may constitute a sale or sharing of personal information under CPRA for California residents. For EEA users, the use of non-essential tracking technologies requires consent under the ePrivacy Directive as implemented in EU member states.
Interpretive note: The specific list of advertising and analytics partners and the scope of data shared with each is not enumerated in the document, making it difficult to assess the full extent of third-party data flows.
The updated terms now explicitly disclose that Coursera processes communications through voice-enabled features that transcribe audio into text, and clarify that personal data may be shared with third parties including affiliates and business partners. The policy expands descriptions of AI-driven personalization and chatbot applications that use your learning and interaction data. The terms establish that data may be transferred to entities that become Coursera affiliates or subsidiaries during business transitions. You should review the updated guidance that cautions against including unnecessary or sensitive personal data in the platform's free-text and voice-enabled communication features.
View change record →The updated Privacy Notice removes explicit language stating that the policy does not apply to Coursera's Ollie mobile application and no longer directs users to a separate Ollie Privacy Notice for that app. Previously, users of Ollie had clear notice to consult a dedicated privacy policy; that direction is now absent from the main Privacy Notice. The updated notice also narrows the scope of covered entities by removing 'affiliates' from the definition of Coursera, stating the policy now applies to Coursera, Inc., its subsidiaries, and international branches only. Users of the Ollie App should independently verify what privacy terms currently govern that application, as the main Coursera Privacy Notice no longer explicitly addresses Ollie coverage.
View change record →Under this clause, Coursera authorizes third-party advertising and analytics partners to collect device identifiers and behavioral data through tracking technologies while users interact with the platform. California residents may opt out of the sale or sharing of personal information; EEA users may manage cookie consent through applicable consent mechanisms.
How other platforms handle this
We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...
We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your personal information with busines...
We may disclose personal information to advertising and analytics providers in connection with the provision of tailored advertising, to monitor the performance of advertisements displayed on our behalf on the Services and across the Internet, to provide analytics services, and to help improve our S...
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"We use advertising technologies and analytics providers to help deliver relevant advertising and to understand how you interact with our Services. These third parties may use cookies, web beacons, and similar tracking technologies to collect information about your use of our Services and other websites.— Excerpt from Coursera's Coursera Privacy Notice
REGULATORY LANDSCAPE: This provision engages the ePrivacy Directive and GDPR for EEA users, CPRA for California residents, and the FTC Act for general consumer data practices. The use of third-party tracking for advertising purposes requires documented consent or opt-out mechanisms depending on jurisdiction. The FTC has issued guidance on cross-context behavioral advertising and data broker practices. GOVERNANCE EXPOSURE: Medium. The use of third-party advertising technologies on an educational platform serving learners of varying ages creates compliance considerations, particularly if minors are among the user base. COPPA may apply if users under 13 are served targeted advertising. JURISDICTION FLAGS: California creates the most immediate regulatory exposure under CPRA's opt-out of sale/sharing requirements. EEA and UK users require documented consent for non-essential cookies. States with comprehensive privacy laws (Virginia, Colorado, Connecticut, Texas) may also require opt-out mechanisms for targeted advertising. CONTRACT AND VENDOR IMPLICATIONS: Compliance teams should audit the list of advertising and analytics partners receiving data, confirm data processing agreements are in place, and assess whether cross-border data transfers for advertising purposes are covered by adequate transfer mechanisms. Vendor contracts should address permissible use limitations on learner behavioral data. COMPLIANCE CONSIDERATIONS: Organizations should review whether Coursera's cookie consent and opt-out mechanisms satisfy applicable requirements in deployed jurisdictions. For California-based deployments, confirm that the 'Do Not Sell or Share' opt-out is surfaced appropriately. GDPR-subject deployments require documented consent workflows for non-essential advertising cookies.
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This provision authorizes the use of cross-site tracking technologies and sharing of behavioral data with advertising and analytics partners, which may constitute a sale or sharing of personal information under CPRA for California residents. For EEA users, the use of non-essential tracking technologies requires consent under the ePrivacy Directive as implemented in EU member states.
Under this clause, Coursera authorizes third-party advertising and analytics partners to collect device identifiers and behavioral data through tracking technologies while users interact with the platform. California residents may opt out of the sale or sharing of personal information; EEA users may manage cookie consent through applicable consent mechanisms.
ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.
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