Coursera · Coursera Privacy Notice · View original document ↗

Coursera as data controller or processor

High severity Medium confidence Explicitdocumentlanguage Common · 299 of 352 platforms
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Recent governance activity Coursera recorded 2 documented changes in the last 30 days.
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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)

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.

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 →

Consumer impact (what this means for users)

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

ZipRecruiter Medium

authorize ZipRecruiter to connect your account to the account of a "Connected Site" (e.g., Google, LinkedIn, Monster, Facebook or Twitter), we may be able to access information you have provided to the Connected Site...

NVIDIA NIM Medium

telemetry information collected includes: (i) microservice settings, (ii) usage data and (iii) hardware environment.

Glassdoor Medium

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.

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▸ View Original Clause Language DOCUMENT RECORD
"
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 Coursera Privacy Notice

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
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 21, 2026
Last verified
July 9, 2026
Record ID
CA-P-028884
Document ID
CA-D-00158
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3c5d29b9e68e11ce59e899d357a4125c9cdd43a884fc699ab73522c51379edab
Analysis generated
May 21, 2026 05:07 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coursera
Document: Coursera Privacy Notice
Record ID: CA-P-028884
Captured: 2026-05-21 05:07:28 UTC
SHA-256: 3c5d29b9e68e11ce…
URL: https://conductatlas.com/platform/coursera/coursera-privacy-notice/provision/CA-P-028884/coursera-as-data-controller-or-processor/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Coursera's Coursera as data controller or processor clause do?

The distinction between controller and processor determines who bears primary legal responsibility for data processing decisions and who users must direct rights requests to.

How does this clause affect you?

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 many platforms have this type of clause?

ConductAtlas has identified this type of provision across 299 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.