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
The distinction between controller and processor determines who bears primary legal responsibility for data processing decisions and who users must direct rights requests to.
Interpretive note: The excerpt specifies 'degree program' as the condition triggering processor status, but it is unclear whether other for-credit programs trigger the same shift. Only 'degree program' is named in the excerpt and is therefore the only condition stated in the canonical claim.
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 →Your data rights and Coursera's legal obligations toward you differ depending on whether you are in a degree program, where Coursera's role shifts from controller to processor.
How other platforms handle this
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
telemetry information collected includes: (i) microservice settings, (ii) usage data and (iii) hardware environment.
Some of our ad partners may also enable us to collect similar data directly from their website or app by integrating our or our affiliates' advertising technology.
"Coursera, Inc. is the data controller of the Personal Data...we determine the means and purposes of collecting, using, storing, disclosing, or otherwise processing your Personal Data. However, if you are participating in a degree program...Coursera is the data processor.Excerpt from Coursera's Privacy Notice
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The distinction between controller and processor determines who bears primary legal responsibility for data processing decisions and who users must direct rights requests to.
Your data rights and Coursera's legal obligations toward you differ depending on whether you are in a degree program, where Coursera's role shifts from controller to processor.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
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