Privacy Policy
Last Modified: January 5th, 2024
GUIDE TO CONTENTS
USER CONTROL OF PERSONAL INFORMATION
YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY):
RESIDENTS OF THE EUROPEAN ECONOMIC AREA
INTRODUCTION
Welcome to Noodle Partners, PBC (“Noodle” or “we” or “us”). Noodle manages online academic programs, non-credit courses, and certificates (“Program”) for our partner colleges and universities (“University”) and also provides students, parents and educators access to a comprehensive network of information and services to enable the discovery of educational opportunities at every stage of learning. This Privacy Policy applies to the about.noodle.com website and any associated landing pages or learning platforms.
Because Noodle values your privacy, we have created this Privacy Policy to explain how we collect information from and about you when you use the Noodle Services (as defined in our Terms of Service) and how we may disclose and use that information.
This Privacy Policy applies to all users of the Noodle Services, including, without limitation, all users designated as Experts (as defined in our Terms of Service) by Noodle, and whether a user has registered for an account with the Noodle Services or not. This Privacy Policy applies to Noodle’s collection and use of personally identifiable information, which is information that can be used to identify or contact a specific person, such as a full name or email address, as well as our practices for handling non-personally identifiable information, such as user preferences and services usage information.
By visiting or using the Noodle Services, you agree to the terms and conditions and this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please leave this site immediately and do not use or access the Noodle Services.
COLLECTION OF INFORMATION
We collect information to provide services to all of our users and to improve our Noodle Services. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations. We store the information we collect with unique identifiers tied to the browser, application, or device you’re using.
Noodle and our service providers may collect the following information from and about you:
- First name and last name
- Email address
- Phone number
- Zip code
- Program of interest
- Level of education Attained
- Whether or not you’ve taken an admissions exam
- Years of work experience
- Gender
- Picture
- Education history
- Areas of interest which you have explicitly declared, as well as what we can infer from your engagement with our products and services
- Your marketing and newsletter preference
- Any data recoverable from social networking sites, where permission from you has been obtained; such as your name, picture, email address, gender, zip code and birthday, and whether you are a student, parent, or educator and
- any other information that you submit to us
Registration Information
Registering for a free account on the Noodle Services is the best way to engage with the features that we offer. When you register for an account or when you sign up for other features that we may offer on the Noodle Services (such as a newsletter or a contest or sweepstakes), we may ask you to provide certain information. You do not have to give us any personal information in order to browse our websites. However, if you wish to register on our website, use the Noodle Service, request further information, contact us, complete any surveys, register for any Programs or provide content for inclusion on our website, we will collect certain data, including personal information.
Information from Social Media and Other Sites
You may have the option to sign up for the Noodle Services through a social media service (e.g., Facebook) or another third-party site. If you sign up for a Noodle account in this way, we may collect information about you from that service or site, which may include the username associated with that service or site, your name, profile picture, email address, gender, birthday or friends lists, your likes, preferences, searches, comments and posts, and any other information or content of yours collected by that service or site. All information from and about you that is collected from social media services and third-party sites in this manner may be used and disclosed by Noodle in accordance with this Privacy Policy.
Public Information and Posts
Noodle helps make the educational experience social by permitting users to post content and comments on, and otherwise contribute materials and information to the Noodle Services. Please keep in mind that such posts and contributions may be public depending on the context in which they are shared, which means they are available to others and may be displayed in search results on external websites and search engines. In addition to the content, comments and other materials and information that you post and contribute, we may collect the information about you that accompanies those comments, content and other materials and information, such as your name, user name, comments, email address, profile information and picture.
Activity Information
When you access and interact with the Noodle Services, we may collect certain information about those visits, such as your searches and preferences as well as technical information about your computer and its operating system, your internet browser, your internet protocol address, your navigation path (including your navigation on the Noodle Services and the domain names of the sites from and to which you link), and other information about your software and hardware. If you access the Noodle Services from a mobile or other device, we may collect certain information including the unique device identifier assigned to that device, geolocation data, your wireless service provider, operating system, browser type and other transactional information for that device.
Use of Web Beacons
Some of our web pages may contain electronic images known as Web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
We may also use web beacons or similar technology to learn whether or not emails sent to you have been opened.
Cookies and California Do Not Track Disclosures
Cookies are small bits of data that a site or its service provider transfers to your computer through your browser that enables the site or service provider to recognize your browser and remember certain information about you. We may use cookies and other tracking technologies (such as pixel tags, ad tags and web beacons) to collect information to help us understand your interactions with the Noodle Services, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. Third parties that support the Noodle Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate usage statistics, (e.g., Google Analytics tracking and Google AdWords) may also use these technologies to collect similar information. Noodle does not control these third-party technologies and their use is governed by the privacy policies of the third parties using such technologies. Your browser may permit you to disable these technologies. However, doing so may prevent you from using certain parts of the Noodle Services. See the cookies policy for more information.
If you would like to delete cookies or instruct your web browser to disable tracking please visit the help pages on your web browser. However, doing so may prevent you from using certain Noodle Services. Please note that Noodle does not respond to “Do Not Track” settings configured in your web browser.
Information from Other Sources
We may supplement the information we collect through the Noodle Services with information from other sources, such as information that you submit to Noodle directly by email, telephone or other means (e.g., information you provide to Noodle’s customer service team) and publicly available information from social media services, commercially available sources and information from our affiliates or business partners.
Legal Basis For Processing Your Personal Information
We collect and process information about you only where we have a legal basis for doing so under applicable law. The following are the legal bases for collecting and processing your Personal Information:
When you give us your consent to do so, this includes:
- Where consent is required by law, and where we ask for your consent to process your Personal Information for a stated purpose.
- Where we rely on your consent to process your Personal Information, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make the processing which we undertook before you withdrew your consent unlawful.
To meet contractual obligations or obligations related to a contract, this includes:
- Providing the Noodle Services and their features to you.
- Providing you with customer support.
- Responding to your communications and requests.
- Communicating with you.
- Creating an account and profile for you.
For Noodle’s legitimate interests, this includes:
- Developing and operating our business.
- Maintaining and improving our products and the Noodle Services.
- Operating our site and providing the Noodle Services.
- Conducting market research, audits, and other business operations.
For purposes which are required by law, this includes:
- Complying with any regulations, procedures, and laws which apply to us.
- Investigating misuse of your account.
USE AND DISCLOSURE
When information collected from or about you does not identify you as a specific person, Noodle may use that information for any purpose or share it with third parties who may use it for any purpose. When information collected from or about you is personally identifiable (your “Personal Information”), Noodle and our service providers may use and disclose that information in the following ways:
To provide and personalize the Noodle Services
We use your Personal Information to provide the requested Noodle Services and its features to you, including: to improve the Noodle Services and its features, to personalize the Noodle Services, and to improve your experience with the Noodle Services by delivering content and advertising you will find relevant and interesting, by customizing search results generated by your queries, and by making recommendations based on your preferences; to allow you to post, share and comment on content; and to provide you with customer support and to respond to inquiries.
To manage your participation in the Program
We may use the Personal Information that we collect from you when you participate in the Program for administrative purposes, including but not limited to tracking attendance, progress of the course or Program, and completion of the Program.
To allow service providers to assist us in providing and managing the Noodle Services
Noodle may make your Personal Information available to certain third party service providers solely for the purpose of helping us with our business operations, such as data processing, marketing, recruiting, placement, and technology services.
To allow social sharing functionality
By logging in with or connecting your Noodle Services account with a social media service or third-party site, you are authorizing us to share your Personal Information with the social media service or third-party site provider and other users and your friends on that service or site and you understand that use of such shared information by the social media service or third-party site provider will be governed by its privacy policy. If you do not want your Personal Information shared in this way, please do not connect your social media service or other third-party account with your Noodle Services account and do not participate in social sharing on the Noodle Services.
To deliver relevant advertisements
Noodle and our service providers may use your Personal Information to deliver relevant advertisements to you when you use the Noodle Services or another service. As noted above, third-party advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and activity, including but not limited to information about your visits to websites to display advertisements more tailored to your interests and to provide you the most relevant advertising. If you wish to know more about this practice or would like to know more about your options, you can visit the Network Advertising Initiative (“NAI”) web-site. The NAI is a cooperative of online advertising companies who are committed to responsible practices and consumer protection.
To contact you
Noodle may periodically send you promotional materials or notifications related to Noodle and the Noodle Services and related products or services. These emails are meant to be useful to you while helping us improve our user experience. However, if you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email.There are certain service notification emails that you may not opt-out of, such as notifications of changes to the Noodle Services, policies, or informational emails about your registration in a Program.
To share with our Noodle Affiliates
Noodle may share your Personal Information with our affiliates for the purposes described in this Privacy Policy.
To protect the rights of Noodle and others
There may be instances when Noodle may disclose your information, including situations where Noodle has a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Noodle; (ii) protect the safety, privacy, and security of users of the Noodle Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.
To complete a merger or sale of assets
If Noodle sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Noodle may transfer your Personal Information to the party or parties involved in the transaction as part of that transaction.
The categories of third parties to whom we disclose or sell Personal Information for our business purposes are:
- Affiliates of Noodle for the purposes described in this policy.
- Providers of those Noodle Services that you are interested in.
- Educational institutions that you are interested in.
- Third party service providers solely to assist us in providing and managing our services, such as data processing, marketing, and technology.
- To third parties to protect the rights of Noodle and others.
USER CONTROL OF PERSONAL INFORMATION
Personally identifiable Information
Please do not submit to us or post on the Noodle Services any personally identifiable information that you do not want us to collect. In particular, we ask that you not send us, and you not share, any sensitive information, such as social security numbers, on or through the Noodle Services. Please keep in mind that, although you are not required to provide any personally identifiable information that we request, in many cases, if you do not provide us with the requested information, we may not be able to provide you with certain services or respond to any questions you may have.
Receiving electronic communications from us
If you no longer want to receive emails from us on a going-forward basis, you may opt-out of receiving these emails by following the unsubscribe instructions in the email footer. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your personally identifiable information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent.
Canceling your account
While your account is active, we retain your Personal Information. If you cancel your account or if we terminate your account for any other reason, we may continue to retain your Personal Information for reasons including, but not limited to, complying with our legal obligations or our internal security policies, meeting regulatory requirements, for fraud detection, providing you the Noodle Services that you have signed up for, improving our site and services, or enforcing this Privacy Policy. Remember that even after your account is canceled, copies of some information from your account may remain viewable in some circumstances, for example, where you have shared information with a third-party application or web site or where you have posted your Personal Information publicly on the Noodle Services. In addition, because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the internet and from search engines.
SECURITY
The security of your information is very important to us. To safeguard the Personal information of the users of the Noodle Services, Noodle has chosen to use a proven method of securing its data and business supporting technologies. By employing the International Standards Organization’s (“ISO”) 27001 standard, which formally specifies an Information Security Management System, Noodle follows a mature program for the assurance of information security. However, due to the inherent open nature of the Internet, no data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, while we take measures to protect your Personal Information, we cannot ensure or guarantee the security of any information you send to us or that we store on our servers. Your use of the Noodle Services demonstrates your assumption of this risk.
DATA TRANSFERS
Personal Information collected by Noodle may be transferred to, stored, and processed, in your country and in the United States, or any other country where our service providers process information. Our service providers are required by contract to safeguard this Personal Information and are prohibited from using it for any purpose other than to perform the services instructed by Noodle. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in our Privacy Policy. We also take steps to provide adequate protection for any transfer of your Personal Information in accordance with applicable law.
LINKED SERVICES
The Noodle Services may contain links to third-party services and sites, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. Noodle is not responsible for the privacy practices or content of such third-party services and sites and unaffiliated companies. Once you leave the Noodle Services or click an advertisement you will be bound by, and should review the applicable privacy policy of, the other site or service.
SOCIAL MEDIA
The Noodle Services may contain links to our presence on various social media platforms. We do not operate or control these platforms. You should be aware that personally identifiable information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control these uses of your personally identifiable information, and by using such services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties
OTHER IMPORTANT INFORMATION
PROTECTION OF CHILDREN
The Noodle Services are not targeted to children, and we do not knowingly collect personally identifiable information from children younger than 16 years of age. If we become aware that personally identifiable information from a child younger than 16 years of age has been collected without the consent of such child’s parent or guardian, we will delete such information from our database without requesting permission to do so.
YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY):
Under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA), California consumers are entitled to disclosures regarding the collection and use of their Personal Information. This section describes your CCPA rights and how to exercise those rights.
Collection and Disclosure of Personal Information
In the past 12 months, we have collected, and may have disclosed or sold to third parties for our business purposes, the following categories of Personal Information relating to California residents:
- First Name and Last Name
- Email Address
- Phone Number
- Location
- Education History
- Gender
- Picture
- Information from social media and other sites
- Usage Data
- Preferences
Other Personal Information described in the section above titled “Collection of Information” may have been collected.
Our website does not target consumers under 16 years of age. Noodle has no actual knowledge of its selling, sharing, or collection of any personal information from any consumer under 16 years of age.
The categories of sources from whom we collected this Personal Information
Categories of sources from whom we collect Personal Information are described above under the section titled “Collection of Information.”
Purposes of collecting Personal Information
We collect the Personal Information described above to provide the Noodle Services to all of our users, to improve our services, and for our business purposes. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations, and for the purposes described under the section titled “Use and Disclosure.”
The categories of third parties to whom we disclose or sell Personal Information for our business purposes are:
- For more information, please see the section “Use and Disclosure” in our Privacy Policy.
Rights of California Consumers under the CCPA
If you are a California resident you have a right to request that we provide you with the following information from 12 months prior to your request:
- The categories of personal information that we have collected about you.
- The categories of sources from which the personal information was collected.
- The business or commercial purpose for collecting personal information about you.
- The categories of third parties to whom we disclosed your personal information.
- The specific pieces of personal information we have collected about you and may have shared or sold.
- The categories of information that we sell or disclose to third parties.
You have the right to request that we delete or correct any Personal Information we may have collected about you, unless the CCPA recognizes an exception. You also have the right to request to access the information we have about you. If you would like to exercise your right to request to delete or correct your information or know about your information under the CCPA you may do so with this Form.
The CCPA prohibits discrimination against any consumer for exercising any of the rights described above. You have the right for us to process your request free of charge within 45 days of us receiving a verifiable consumer request to know what information we have collected about you, to correct inaccurate personal information, or delete your personal information.
Sale of Personal Information
Under the CCPA a consumer shall have the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s Personal Information. You have a right for us to process your request within 15 days of receiving it.
Depending on your jurisdiction, you may request to opt-out of the sale or sharing of your personal information at Do Not Sell or Share My Info or by contacting us at privacy@noodle.com.
You may also submit a written request to this address: 60 Chelsea Piers, 2nd Floor, Room 6020, New York, NY 10011. Please provide your full name, contact information, and a detailed description of your request.
The CCPA defines the sale of information broadly. The sharing of your information with universities or service providers may be considered a “sale” of your information under the CCPA. We do not sell or share your information for financial gain.
Authorized Agent
A California resident may use an authorized agent to submit requests to opt-out of the sale of their Personal Information, delete their Personal Information, correct inaccurate personal information,and know about their Personal Information that has been collected. To use an authorized agent, the California resident must provide the agent with written authorization and the California resident may be required to verify their identity with Noodle. We may reject the request of an authorized agent that does not provide proof of authorization. Please submit a detailed request and proof of authorization to privacy@noodle.com.
RESIDENTS OF THE EUROPEAN ECONOMIC AREA
GDPR PRINCIPLES
Noodle complies with the principles of the GDPR and adheres to the principals that Personal Information shall be:
- Processed lawfully, fairly and in a transparent manner in relation to the person.
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
- Accurate and, where necessary, kept up to date.
- Kept in a form which permits identification of persons for no longer than is necessary for the purposes for which the Personal Information is processed.
- Processed in a manner that ensures appropriate security of the Personal Information.
If you reside or are located in the EEA you have the right, under certain circumstances, to request that we:
- Erase your Personal Information without undue delay.
- Provide you with your personal information in a structured, commonly used and machine-readable format.
- Rectify any inaccurate Personal Information concerning you.
- Restrict the way we process your Personal Information.
- Inform you about what Personal Information we collect about you.
- Don’t subject you to a decision based solely on automated processing.
- Do not process your Personal Information and that we do not provide your Personal Information to third parties.
Noodle is the data controller, which means that we are responsible for responding to your requests in relation to how your Personal Information is used. If you have any privacy concerns or if you would like to exercise any of your statutory rights described above please let us know by submitting this form. You may use this same email address to contact Noodle’s Data Protection Officer. We will address your request or inquiry without undue delay.
ADDITIONAL JURISDICTIONS
If you reside in a covered jurisdiction, you may be entitled to exercise various privacy rights. To opt out of the sale or sharing of your personal information, please click here. To exercise additional rights that may be available to you, please click here.
DIGITAL PRIVACY FRAMEWORK (“DPF”) PRINCIPLES
The EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. Data Privacy Framework (UK Extension to the EU-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) were developed to facilitate transatlantic commerce by providing U.S. organizations with reliable mechanisms for personal data transfers to the United States from the European Union / European Economic Area, the United Kingdom (and Gibraltar), and Switzerland that are consistent with EU, UK, and Swiss law. Noodle is committed to adhering to its principles, and is in the process of certifying this commitment under the DPF’s requirements.
Federal Trade Commission Jurisdiction
The Federal Trade Commission has jurisdiction over Noodle’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Noodle may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Collection of Information
For information on the personal information Noodle collects about you, the purposes for which it collects the data, and the type of third parties to which it shares this data, please see above in our Privacy Policy the sections on Collection of Information, Use and Disclosure, and our California Privacy Rights, respectively.
Opt-Out and Access
Under the EU-US DPF, you may access the data Noodle has collected from you and opt out of Noodle’s sharing your personal information with a third party here (for sharing your information with third parties), and here (for accessing your data).
Independent Dispute Resolution
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Noodle commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit here for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Binding Arbitration
You may invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other mechanisms set out in this DPF portion of our Privacy Policy. For more information, please see Annex 1 of the DPF Principles, available here.
Onward Transfer Principle
Under the Onward Transfer Principle of the DPF, Noodle remains responsible and liable for any personal data from the EU, the UK (or Gibraltar), or Switzerland that we share with third parties for external processing on our behalf.
U.S. Entities or Subsidiaries of Noodle
The U.S.-based subsidiary of Noodle also committed to complying with the principles of the DPF is Meteor Learning, Inc.
Inquiries or Complaints
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Noodle commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Noodle at privacy@noodle.com.
UPDATING YOUR PERSONAL INFORMATION
You may review, correct, update or change your personal information at any time by contacting us at privacy@noodle.com. Often, where you have signed up for an online account on one of our websites you may also be able to update your details via that online account.
RETENTION
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. This retention period may be extended if any applicable statutory or regulatory obligation requires us to hold information for a longer period.
UPDATES THIS PRIVACY POLICY
We may modify this Privacy Policy. Please look at the date above to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on Noodle’s web pages and landing pages. Policy changes will apply only to information collected on and after the date of the change.
HOW TO CONTACT US
As a reminder, if you have any questions about this privacy policy or your personal information, please contact us at privacy@noodle.com.