Provision record
Coursera · Coursera Privacy Notice · View original document ↗

Cross-Border Data Transfers

Medium severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Your personal data is stored and processed in the United States, even if you are in a country with stronger privacy laws such as those in the EU or UK.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

EU, UK, and other non-U.S. users should be aware that their data is transferred to a jurisdiction with a different legal framework, and the adequacy of transfer mechanisms is a material compliance consideration.

Interpretive note: The specific transfer mechanism (SCCs, DPF, or other) is not identified in the document, creating uncertainty about the legal basis for EU/UK to U.S. transfers.

Recent Activity

This document changed recently

Medium May 11, 2026

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 →
Medium Apr 18, 2026

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
May 8, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

Non-U.S. users' personal data is transferred to and processed in the United States, which may involve reduced statutory protections compared to their home jurisdiction, depending on the transfer mechanism Coursera employs.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    EU and UK users who wish to exercise rights related to cross-border data transfers, including requesting deletion of personal data held in the U.S., can submit a request to privacy@coursera.org.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Coursera is a U.S.-based company and your personal data will be processed in the United States. If you are located outside the United States, the data protection laws of the United States may differ from those in your country.

Excerpt from Coursera's Privacy Notice

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (international data transfers), the UK GDPR equivalent transfer rules, and any applicable adequacy decisions or standard contractual clauses (SCCs) required to legitimize transfers from the EU/EEA and …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Coursera Privacy Notice
Entity
Coursera
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-006203
Document ID
CA-D-00158
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
59834b4e08e538f4b11e3db8b297dc7b75811100ba60ce40b60950ff40b3b3a6
Analysis generated
May 10, 2026 18:17 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coursera
Document: Coursera Privacy Notice
Record ID: CA-P-006203
Captured: 2026-05-10 18:17:25 UTC
SHA-256: 59834b4e08e538f4…
URL: https://conductatlas.com/platform/coursera/coursera-privacy-notice/provision/CA-P-006203/cross-border-data-transfers/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Coursera's Cross-Border Data Transfers clause do?

EU, UK, and other non-U.S. users should be aware that their data is transferred to a jurisdiction with a different legal framework, and the adequacy of transfer mechanisms is a material compliance consideration.

How does this clause affect you?

Non-U.S. users' personal data is transferred to and processed in the United States, which may involve reduced statutory protections compared to their home jurisdiction, depending on the transfer mechanism Coursera employs.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Coursera?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coursera.