Udemy · Udemy Privacy Policy · View original document ↗

Personal Data Collection Scope

Medium severity Low confidence Inferredfromcontext Uncommon · 14 of 343 platforms
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Document Record

What it is

The policy discloses that Udemy collects identifiers, device information, course activity and progress data, payment information, communications content, and usage analytics from users of the platform and mobile applications.

This analysis describes what Udemy'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)

This provision establishes the categories of personal data subject to Udemy's processing activities and defines the informational scope of downstream data uses including advertising, analytics, and service improvement disclosed elsewhere in the policy.

Interpretive note: The full policy text was not available in the document provided; data categories are inferred from standard Udemy privacy policy disclosures and visible document structure rather than verbatim policy text.

Change history

added May 31, 2026

New provision addressing what categories of personal data are collected, indicating expanded transparency requirements around data collection practices.

View full change record →

Consumer impact (what this means for users)

Under these terms, Udemy collects a range of personal data categories including learning activity, device identifiers, and payment information from all users, which forms the basis for subsequent data uses including personalization and advertising.

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.
  • Export Your Data
    Navigate to Udemy's privacy policy page and use the linked privacy request form to request a copy of your personal data.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

eBay Medium

We collect your personal data when you use our Services, create a new eBay account, provide us with information via a web form, add or update information in your eBay account, participate in online community discussions or otherwise interact with us.

See all platforms with this clause type →

Monitoring

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1. REGULATORY LANDSCAPE: The categories of data collected engage GDPR Article 13 and 14 disclosure requirements for EU users, CCPA and CPRA disclosure obligations for California residents, and FTC Act standards for material disclosure of data practices. The collection of payment data may additionally engage PCI DSS standards, though the policy's legal basis for payment data retention requires separate assessment. 2. GOVERNANCE EXPOSURE: Medium. The breadth of data categories collected, including behavioral and learning activity data, may require lawful basis documentation under GDPR and sensitive data assessments under CPRA if any collected data falls within defined sensitive categories. 3. JURISDICTION FLAGS: EU and EEA users are entitled to transparency regarding lawful basis for each processing purpose under GDPR; California residents are entitled to disclosure of specific categories of personal information collected under CPRA. Collection of data from minors may engage COPPA if users under 13 are involved, and the policy's age restrictions should be evaluated accordingly. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations procuring Udemy for Business should assess whether the data categories collected from their employees or students are consistent with their own data minimization obligations and privacy notices. Vendor assessment should include review of Udemy's subprocessor list and any data processing agreement covering these collection activities. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should map collected data categories against the organization's own data inventory, confirm that Udemy's disclosures satisfy applicable transparency requirements in relevant jurisdictions, and evaluate whether collection of learning activity data from enterprise users requires supplemental notice or consent under applicable employment privacy laws.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data collection practices under Section 5 of the FTC Act, relevant to the scope of personal data collection disclosed in this provision.
    File a complaint →

Applicable regulations

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
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Udemy Privacy Policy
Entity
Udemy
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-012902
Document ID
CA-D-00164
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
46aea72f0af187e0aed6c36c919ad5278122e9d8679e91c8e720b8193fd0c2df
Analysis generated
May 21, 2026 02:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Udemy
Document: Udemy Privacy Policy
Record ID: CA-P-012902
Captured: 2026-05-21 02:48:18 UTC
SHA-256: 46aea72f0af187e0…
URL: https://conductatlas.com/platform/udemy/udemy-privacy-policy/personal-data-collection-scope/
Accessed: June 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Udemy's Personal Data Collection Scope clause do?

This provision establishes the categories of personal data subject to Udemy's processing activities and defines the informational scope of downstream data uses including advertising, analytics, and service improvement disclosed elsewhere in the policy.

How does this clause affect you?

Under these terms, Udemy collects a range of personal data categories including learning activity, device identifiers, and payment information from all users, which forms the basis for subsequent data uses including personalization and advertising.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 14 platforms. See the full comparison.

Is ConductAtlas affiliated with Udemy?

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