Data Privacy Policy

Data Privacy Policy

What is covered in this policy?

This privacy policy covers but not limited to CLASS LLC, and its affiliated products such as the platform,, Heuristic Solutions and any applications that are the properties of CLASS LLC at present and future.

The description of the privacy policy details how CLASS collects, uses and discloses your data as well as your rights to object or consent to our process. CLASS understands and respects your rights and is committed to protecting your privacy and personal data through our compliance with the applicable law. Should complains arises due to the discrepancy between the clauses used in this privacy policy and how the policy is executed, CLASS will try its best to resolve the issue in accordance with the law. More information about your rights, and how to exercise them, is listed in the session of Managing your personal information. CLASS reserves its right to revise and update this policy whenever needed. When the change happens, we will communicate with you via the contact method you provide.

How do we collect, use and disclose the data?

Collect information

a. Information we receive

CLASS collects information you agree to provide to us when you submit a web form such as registration, set up an account or request any information from CLASS through the platform. The information we collect includes such personal information as

      • Full name and user name
      • Mailing address and billing address if it is different from mailing address
      • Email
      • Telephone number
      • Educational background
      • Working experience
      • The information in the communications with CLASS
      • Your information provided by organizational representatives via phone, email, online forms, surveys, in-person meetings, etc
      • Your information in any contract or legal obligation that CLASS performs.

b. Information passively collected

We and/or our partners use cookies and other technologies to automatically collect information when you interact with the platform such information includes:

      1. Your computer IP
      2. Your computer OS (Operating System)
      3. Mobile device and its type and model
      4. Browser type and version
      5. Your search activities including information you find on the website
      6. Your interest in the clickable ads on the site

To get better ideas how we use cookies and other technology to track the information, and how you can set up the control of cookies on your browser, please read “Cookie Policy” session below. You may restrict or decline cookies. However, if you limit or decline cookies, you may not be able to access to certain contents or some parts of the platform.

c. Use the information

We use your personal information, to which you consent, for the following purposes:

  • To identify who you are in order to give you the access to use the services and contents of CLASS when you set up or sign in your CLASS account
  •  To use your account information for verification purpose including transaction confirmation, billing, authentication and security
  •   To contact you for the purposes of customer service, technical supports, any legitimate business requests and responding to your questions or concerns 
  •   To research the trend of using the contents and services, to analyze your interaction with the website, to solicit feedback and comments so as to enhance our current services by developing new products and services to better address your needs
  •   To understand the differences between various user groups in order to provide more relevant contents and services that optimize the usability
  •   To market or keep you informed about any services, offers, competition opportunities, surveys and events that may interest or benefit you
  •   To keep your record accurate, up-to-date, secure and safe

d. Disclose Information

With your consent, CLASS shares your information with all CLASS-affiliated services or products to inform you about any new programs or contents of CLASS

We share your information with any third party business that provides services to CLASS. Such services include but not limited to the platform hosting, maintenance, technical support, payment service or any other service that is an essential part of CLASS’ business. CLASS provides these service providers only the information that is necessary to process your information and/or provide services to CLASS. These service providers are not allowed to use or share your information for any other purposes. Where permitted by law, CLASS discloses necessary information about you to some service providers to serve relevant advertising on third party platforms to you or to other audiences.

When requested by applicable law, regulations or government, we need to share your information.

For the security reason, we disclose your information to conduct investigation on potential violations or detect and prevent any potential fraud.

We may use your information when it is necessary for us to investigate, prevent, or take action against any malicious activities or attempts to compromise the security of the Website infrastructure or the Services in general

CLASS may sell its assets or be acquired by another entity. In such a case, your information may be transferred to the new entity, which should take the responsibility of protecting your information protected by this Privacy Policy.

Information Security

Protecting the security of your information has utmost importance to us. We develop practical strategies to safeguard your information, and prevent any dubious or unauthorized access or use of your information. While we make efforts to ensure the accuracy, safety, and security of your information, you are also expected to make the same efforts for the same reason. Information such as your passwords, payment information or any information related to your privacy should be kept confidential and not shared with anyone. As online communication of information is not entirely secure, even though we do our best to protect your information, we are not able to guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information.

We retain your personal information for as long as we have a relationship with you. We also may retain your personal information for longer period of time which enables us to:

  •   Maintain business records for analysis and/or audit purposes;
  •   Comply with record retention requirements under the law;
  •   Defend or bring any existing or potential legal claims;
  •   Address any complaints regarding the services;
  •   Enforce our commercial agreements;
  •   Support our legitimate interests, as described in this Privacy Policy.

Managing Your Personal Information

You can access and/or update your personal information through your user profile. You may ask us for a copy of your personal information, correct, delete, or restrict processing of your personal information with a possible fee permissible by law. In addition, you may have the right under applicable law to object to the processing of your personal information in some circumstances.

Your rights regarding your personal information may be limited, for example, if fulfilling your request would reveal personal information about another person or would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of the relevant exemption upon which we rely when responding to any request you make.

Our use of certain personal information is necessary for us to provide information to you about the 2U-powered programs you may be interest in or to provide services to you through the Website or otherwise. If you choose not to provide this personal information or request that 2U delete or restrict the processing of this personal information, you may not be able to participate in 2U-powered programs, and we may not be able to provide you with other services, including those provided through the Website or advertised about the programs.

If you believe your rights regarding your personal information have been infringed upon, please contact us.

If you wish to access or delete your information as described in this section, please contact CLASS by filling out the Contact Us form.



CLASS uses cookies, a tracking technology in the Platforms, and on all its Applications to make sure the systems identifies you across our different Services, and understand how the web traffic moves for the Services so as to customize and improve the Services. By visiting the Website or using the Services you agree to the use of cookies in your browser and HTML-based emails. Cookies are small text files placed on your device when you visit a web site, in order to track use of the site and to improve your user experience.

Session Cookies

The Services use “session cookies”, which improve your user experience by storing certain information from your current visit on your device, such as log-in information. These enable us to remember your login session so you can move easily within the Website or the other Services. Without these session cookies, we wouldn’t be able to provide the Services to you. Other examples of our use of session cookies include to track the number of visits by a particular visitor to a page.

Performance and Remarketing Cookies

Partners who help us serve advertising on and off the Website and analytics companies may also put cookies on your device. We use several third-party vendors to help deliver ads for relevant CLASS products and services to you when you visit certain pages on our Website and then visit certain third-party sites. We may share with third-party ad partners a cryptographic hash of a common account identifier (such as a User ID), to help us measure and tailor ads and services provided to you. Below is information about one such vendor. Please note that this Privacy Policy covers only our use of cookies and does not include the use of cookies by any third parties.

 a. Google Analytics

CLASS uses a specific cookie in order to facilitate the use of Google Universal Analytics for users logged-in to the Applications or the Platforms (“Logged-In User”). If you are a Logged-In User, CLASS may use your CLASS User ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages of the Services you visit. We do this only to better understand how you use the Website and the other Services, with a view to offering improvements for all CLASS users; and to tailor our business and marketing activities accordingly, both generally and specifically to you. Google Analytics cookies do not provide CLASS with any Personal Information.

Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.

 b. Google Display Advertising

Additionally, CLASS uses Google Analytics code that allows for certain forms of display advertising and other advanced features. Subject to change, the Google Display Advertising features CLASS currently uses are Remarketing, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting

These features are used to advertise online; to allow third-party vendors, including Google, to show you advertising across the Internet; to allow CLASS and third-party vendors, including Google, to use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Website and to report how ad impressions, uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Website. Data from Google’s interest-based advertising or third-party audience data (such as age, gender, and interests) is also combined with Google Analytics to better understand the needs of CLASS users and to improve the Services

You may opt out of such display advertising at any time by visiting your Google Ads Settings page or by installing and running the Google Analytics Opt-out Browser Add-on.

CLASS uses other third-party performance and remarketing cookies, and further information on those third-party cookies can be obtained by contact us.

 CLASS may also use related technologies including web beacons, bugs, pixels, and software tokens in order to facilitate your use of the Services. Most notably, the Services use software tokens (stored securely on Amazon-controlled servers) in order to facilitate the logging in to and the functioning of both the Supported Platforms and Third-Party Apps

Most computers and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies.

Further information can be found here . Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Website, Applications, Platforms, and/or Shop. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive. 


By using any of the Services, or submitting or collecting any Personal Information via the Services, you consent to the collection, transfer, storage, disclosure, and use of your Personal Information in the manner set out in this Privacy Policy. If you do not consent to the use of your Personal Information in these ways, please stop using the Services.

Additional Information

Children’s Privacy

Protecting the safety of children when they use the Internet is very important to us. Our Services should only be accessed by individuals of Minimum Age. “Minimum Age” may mean different ages in different countries, depending on where the individual accesses the services. For reference, “Minimum Age” shall mean (a) 14 years old for the United States, Canada, Germany, Spain, Australia, and South Korea; and (b) 13 years old for all other countries. However, if applicable law requires that you must be older than such ages in order for CLASS to provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then the Minimum Age would be such older age. CLASS’ services are not designed nor intended for use by children or anyone else under the age of 13.


We value you as a CLASS community member. Your compliments, complaints, and suggestions are all important to our growth and improvement.