Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of Udemy to see which features or content users prefer and determine which email messages are opened. Advertising: These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you like your Usage and System Data (as detailed in Section 1), and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non- human-readable form) and content that you share publicly on the Services. Social Media: These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes. You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.

3. What We Use Your Data For We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity. We retain your data for as long as it is needed to serve the purposes for which it was collected. If you have a Udemy account, we will delete your data following account termination, or longer as required by law or necessary for safety and integrity. We use the data we collect through your use of the Services to: Provide and administer the Services, including to facilitate participation in content, issue completion certificates, display customized content, and facilitate communication with other users (Account Data; Shared Content; Learning Data; System Data; Usage Data; Approximate Geographic Data); Process payments to instructors and other third parties (Student Payment Data; Instructor Payment Data); 06/09/2026, 14:20 Online Courses - Learn Anything, On Your Schedule | Udemy https://www.udemy.com/terms/privacy/ 8/22

Process your requests and orders for content, products, specific services, information, or features; confirm delivery; detect fraud or abuse; and enforce Udemy policies (Account Data; Learning Data; Student Payment Data; System Data; Usage Data; Communications and Support); Communicate with you about your account by (Account Data; Shared Content; Learning Data; Promotions, and Surveys; System Data; Communications and Support): Responding to your questions and concerns; Sending you administrative messages and information, including messages from instructors, students, and teaching assistants; notifications about changes to our Service; and updates to our agreements; Sending you information, such as by email or text messages, about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available instructor-created content (which you can opt out of at any time); Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the "options" or "settings" page of the mobile app); Manage your account and account preferences and personalize your experience (Account Data; Learning Data; Student Payment Data; Instructor Payment Data; System Data, Usage Data, Cookie Data); Facilitate the Services' technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (Account Data; Student Payment Data; Instructor Payment Data; Communications and Support; System Data; Usage Data; Approximate Geographic Location); Verify the identity of instructors (Account Data; Instructor Payment Data); Solicit feedback from users (Account Data; Communications and Support); Market products, services, surveys, and promotions (Account Data; Learning Data; Promotions and Surveys; System Data; Usage Data; Approximate Geographic Data; Cookie Data); Market Subscription Plans to prospective customers (Account Data; Learning Data; Cookie Data); Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers (Account Data; Data About Your Accounts on Other Services; Usage Data; Cookie Data); Identify unique users across devices (Account Data; System Data; Cookie Data); 06/09/2026, 14:20 Online Courses - Learn Anything, On Your Schedule | Udemy https://www.udemy.com/terms/privacy/ 9/22

Display and tailor advertisements shown in the Services, including across devices (Cookie Data); Improve our Services and develop new products, services, and features (all data categories), including through the use of AI consistent with the Instructor GenAI Policy (Instructor Shared Content); Analyze trends and traffic, track purchases, and track usage data (Account Data; Learning Data; Student Payment Data; Communications and Support; System Data; Usage Data; Approximate Geographic Data; Cookie Data); Advertise the Services on third-party websites and applications (Account Data; Cookie Data); As required or permitted by law (all data categories); or As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories). We may process your inputs into our generative artificial intelligence (GenAI) features using GenAI in order to respond to your question or request, but we do not use your personal data to train or fine tune GenAI models.

4. Who We Share Your Data With We share certain data about you with instructors, other students, companies performing services for us, Udemy Affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent. We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy: With Your Instructors: We share data that we have about you (except your email address) with instructors or teaching assistants for content you access or request information about, so they can improve their content for you and other students. This data may include things like your country, browser language, operating system, device settings, the site that brought you to Udemy, and certain activities on Udemy, like enrolled courses and course review. We will not share your email address with instructors or teaching assistants. (Account Data; System Data; Usage Data; Approximate Geographic Data) 06/09/2026, 14:20 Online Courses - Learn Anything, On Your Schedule | Udemy https://www.udemy.com/terms/privacy/ 10/22

With Other Students and Instructors: Depending on your settings, your Shared Content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable. (Account Data; Profile Data; Shared Content) With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising and affiliate marketing), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. We require service providers to protect data at a level consistent with this Privacy Policy. (All data categories) With Udemy Affiliates: We may share your data with Udemy Affiliates to enable or support us in providing the Services. (All data categories) With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to Udemy. Depending on your location, we may share your data with these trusted partners. (Account Data; Learning Data; Communications and Support; System Data) With Credit-Granting Organizations for Continuing Education: If you take a course to fulfill a continuing professional education requirement, we may share that information upon request of the organization granting the continuing education credit. (Account Data; Learning Data) With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like ZoomInfo, we share certain contact information or de-identified data. De-identified data means data where we've removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly- available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner and for marketing purposes. (Account Data; System Data; Usage Data; Cookie Data) To Power Social Media Features: The social media features in the Services may allow the third-party social media provider to collect things like your IP address and which page of the Services you're visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company's privacy policy. (System Data; Usage Data; Cookie Data) To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey. (Account Data; Promotions and Surveys) 06/09/2026, 14:20 Online Courses - Learn Anything, On Your Schedule | Udemy https://www.udemy.com/terms/privacy/ 11/22

For Advertising: We may use and share certain Cookie Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect Cookie Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks' behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you'll continue to be served generic ads. (Cookie Data) Google as a Data Controller: Google Ads may use cookies to serve ads based on user profiles from visits to our site and/or other sites on the Internet as well as to measure advertising campaign performance. You can opt out at https://adssettings.google.com. (Cookie Data) For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is: Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding; Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request; Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements; Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; Reasonably necessary in our discretion to protect against harm to the rights, property, or safety of Udemy, our users, employees, members of the public, or our Services; We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or Required or permitted by law. During a Change in Control: If Udemy undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories) After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose. With Benesse Corporation (users in Japan): We may provide your data to Benesse Corporation ("Benesse"), Udemy's exclusive business partner in Japan, and Benesse may 06/09/2026, 14:20 Online Courses - Learn Anything, On Your Schedule | Udemy https://www.udemy.com/terms/privacy/ 12/22