The policy authorizes sharing of user personal data including identifiers, device information, and behavioral data with advertising partners, analytics providers, and other third-party service providers for purposes including targeted advertising and platform analytics.
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
This provision establishes the third-party data sharing relationships that determine how user behavioral and learning data flows beyond the Udemy platform, with direct implications for advertising targeting and cross-context behavioral advertising opt-out obligations under CCPA and CPRA.
Interpretive note: The full policy text was not available; this provision is inferred from standard Udemy privacy policy disclosures and visible document metadata rather than verbatim policy text.
Severity escalated from medium to high, and excerpt content removed from current version (text not provided).
View full change record →Under these terms, personal data including browsing activity and identifiers may be shared with advertising and analytics partners, and California residents may opt out of sharing for cross-context behavioral advertising purposes using the designated opt-out mechanism.
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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.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
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1. REGULATORY LANDSCAPE: Sharing personal data with advertising partners for cross-context behavioral advertising engages CCPA and CPRA's definition of 'sharing' personal information, enforceable by the California Privacy Protection Agency and California Attorney General. GDPR Article 6 requires a lawful basis for such sharing with third parties, and GDPR Article 28 requires data processing agreements with processors. The FTC Act applies to any deceptive or unfair practices in the disclosure or execution of third-party data sharing. 2. GOVERNANCE EXPOSURE: High. Sharing learning activity and behavioral data with advertising partners may constitute 'sharing' under CPRA, triggering opt-out rights and limiting secondary uses of the data by recipients. GDPR compliance requires that each data sharing relationship have a documented lawful basis and that recipients in third countries have adequate transfer mechanisms in place. 3. JURISDICTION FLAGS: California residents have a statutory right to opt out of sharing for cross-context behavioral advertising under CPRA. EU and EEA users' data cannot be transferred to advertising partners in third countries without adequate safeguards such as Standard Contractual Clauses. Illinois, Virginia, Colorado, and other US states with comprehensive privacy laws may impose additional restrictions or opt-out requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should verify that Udemy's data processing agreements with advertising and analytics subprocessors include appropriate contractual protections and that Udemy provides a current subprocessor list. B2B customers should assess whether their own privacy policies and employee or student consents cover data flows to Udemy's advertising partners. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that Udemy's opt-out mechanism for California residents is functional and conspicuously disclosed, evaluate whether advertising-related data flows from enterprise accounts are consistent with applicable employment and education privacy laws, and assess whether GDPR transfer impact assessments are required for advertising partner data flows to non-EEA recipients.
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This provision establishes the third-party data sharing relationships that determine how user behavioral and learning data flows beyond the Udemy platform, with direct implications for advertising targeting and cross-context behavioral advertising opt-out obligations under CCPA and CPRA.
Under these terms, personal data including browsing activity and identifiers may be shared with advertising and analytics partners, and California residents may opt out of sharing for cross-context behavioral advertising purposes using the designated opt-out mechanism.
ConductAtlas has identified this type of provision across 24 platforms. See the full comparison.
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