Privacy Policy

Who We Are

NewU Inc. is a District of Columbia nonprofit corporation recognized under Section 501(c)(3) of the Internal Revenue Code, doing business as "NewU University." Our registered office is at 1156 15th St NW, Suite 605, Washington, DC 20005. Our campus is located at 1400 16th St NW, Suite 710, Washington, DC 20036.

NewU University is accredited by the Middle States Commission on Higher Education. We teach classes for dual enrollment partners, including NewU Dual Academy (Dual Academy Corp.), which means some of the students in our classrooms are high school students, and some are under 18.

You can reach us at [email protected] or 202-968-1001.

Information We Collect

Information you provide directly

When you submit a form on our website, request information, apply for admission, or otherwise interact with us, we may collect:

• Name (first, last)
• Email address
• Mobile phone number
• Mailing address
• Date of birth
• Educational background (high school, graduation year, transfer credits, GPA)
• Military or veteran status
• Family information (parent or guardian name and contact information)
• Application materials (transcripts, identification documents, electronic signatures)
• Financial information necessary for tuition payment, financial aid, or scholarship determination
• Any other information you choose to provide

Information we collect as your school

Once you are enrolled in a NewU class, whether as a degree student or through a dual enrollment partner, we also collect and hold:

• Enrollment and registration records, class selections, and attendance
• Assignment submissions, assessments, grades, and the transcript we issue
• Advising, academic standing, and academic integrity records
• Video and audio recordings of class lectures, including any material the professor presents on screen, as described in the Education Records, Class Recordings, and Proctoring section
• Where a class includes a proctored online assessment, the recordings that proctoring software creates during that assessment
• Accommodation records, where you request an accommodation

Information collected automatically

When you visit our website, we automatically collect:

• IP address and approximate location
• Browser type and version
• Device information
• Pages visited, time spent, and referring URLs
• Cookies and similar tracking technologies (see Cookies section below)

Information from third parties

If you choose to register or log in using a third-party service (such as Google or Facebook), we may receive information from those services consistent with the permissions you grant. Where you enroll in a NewU class through a dual enrollment partner, we receive from that institution the information needed to enroll, instruct, grade, and issue a transcript to you.

How We Use Your Information

We use the information we collect to:

• Respond to your inquiries and provide the information or services you request
• Process applications for admission, financial aid, and enrollment
• Communicate with you about your application, enrollment, and student status
• Deliver instruction, assess your work, award credit, and issue transcripts
• Send you information about NewU programs, events, and university communications by email, SMS, phone, or postal mail (see SMS / Text Messaging section below for SMS-specific terms)
• Process tuition payments and financial transactions
• Verify your identity and prevent fraud, including verifying identity at high-stakes assessments
• Comply with legal, regulatory, and accreditation requirements
• Improve our website, programs, and services
• Conduct internal research and analytics
• Protect the safety and security of students, staff, and our systems

Education Records, Class Recordings, and Proctoring

NewU Inc. is the custodian of the postsecondary education record for every class it teaches, including classes taken by dual enrollment students, and of the recordings of those classes.

FERPA

We handle student education records in accordance with the Family Educational Rights and Privacy Act (FERPA). Rights in a postsecondary education record belong to the student from the start of enrollment, regardless of the student's age. A parent seeking access to such a record obtains a written release from the student. A student may inspect and review their education records, request correction of a record they believe is inaccurate, and consent to disclosures except where FERPA permits disclosure without consent. Requests go to [email protected].

What is recorded

We record class lectures in video and audio, including any material the professor presents on screen, so that enrolled students can review a class they attended or could not attend. Only lectures are recorded. Advising, wellbeing, and disciplinary conversations are not recorded.

What a recording captures

Classes are taught in NewU classrooms that connect students attending online with students attending in person. Those classrooms use a 360 degree camera and microphone placed among the seats. A recording of a lecture with in-person attendance therefore captures the classroom and the people in it, including students other than the person watching it, and includes their faces, voices, names, and what they say during the lecture.

Because we teach dual enrollment classes, an adult degree student may share a class with high school students, including students under 18. The conduct rules for that shared environment are published in the Dual Academy Student and Family Handbook, which students accept at enrollment.

Cameras

A student attending a lecture live is expected to have their camera on, because a class is a discussion rather than a broadcast. A student in a program that permits attendance by recording may instead attend by watching the recording, subject to the deadlines for the class. Where a documented accommodation adjusts the application of the camera rules, it is honored without disclosure of the underlying condition to peers.

Where recordings are held, and who can access them

Recordings are stored in NewU Inc.'s Google Workspace for Education environment with sharing restricted. They are not public, not posted to the internet, and not searchable. Access is limited to the professor of the class, the students enrolled in that class, and designated academic administrators of NewU University and of the enrolling institution. A student may watch a recording of a class in which the student is enrolled, and may not download, copy, re-post, or share it with anyone outside the class.

How long recordings are kept

Class recordings are retained for one academic year and then deleted, unless a recording must be preserved for an investigation or as required by law. This period replaces the general retention periods in the Data Retention section below.

What we do not do with recordings

Exams and proctoring

Some classes include exams or quizzes taken online, and remote proctoring software may be used for those assessments. Remote proctoring runs inside the browser and may record a student's webcam, microphone, and screen during the assessment, and may limit other browser activity while the assessment is open. A class that uses proctoring says so in its syllabus. Proctoring recordings are education records. They are not sold, are not used for advertising or marketing, and are not used to train artificial intelligence or machine learning models.

Your requests about recordings

You may ask what recordings exist of you or of your student, ask to review them, or ask us to delete one. Write to [email protected] and we respond within a reasonable time, and in any event within 45 days. If we cannot delete a recording, for example because it is also another student's education record or must be preserved for a safety matter or by law, we tell you why.

SMS / Text Messaging

NewU University collects mobile phone numbers when you voluntarily provide them through web forms on our website and check the box consenting to receive SMS messages. We use mobile numbers to send admissions, financial aid, enrollment, and related university communications.

Message frequency varies based on your stage in the admissions and enrollment process. Message and data rates may apply.

You may opt out of SMS communications at any time by replying STOP to any message. Reply HELP to any message for assistance, or contact us at [email protected].

For a prospective student under 18 who contacts us directly, we ask that a parent or guardian review and consent to SMS communications. For a student enrolled through a dual enrollment partner, SMS consent is obtained from the parent or legal guardian by the enrolling institution, and messages about a minor student are directed to the parent or guardian number provided. A parent or guardian may contact us at [email protected] to revoke a minor's SMS consent at any time.

Full SMS program terms are available at our SMS Terms of Service page.

How We Share Your Information

We may share your information in the following circumstances:

Service providers

We share information with third-party vendors who provide services on our behalf, such as website hosting, email delivery, SMS messaging (Twilio), customer relationship management, payment processing, analytics, marketing automation, cloud productivity and storage, video conferencing, learning management, and remote proctoring. These providers are contractually obligated to use your information only as needed to perform services for us, and are prohibited from using student data for their own model training or for any purpose unrelated to delivering services to NewU.

School officials

We disclose education records to NewU faculty, administrators, advisors, and contracted staff who have a legitimate educational interest in those records.

Dual enrollment partners

NewU teaches classes for NewU Dual Academy (Dual Academy Corp.) and for schools that enroll students through it. We receive from those institutions the information needed to enroll, instruct, grade, and issue transcripts, including name, date of birth, contact details, and class selections, and we return grades, progress information, and transcript records. NewU Inc. is designated a school official with a legitimate educational interest for this purpose under its agreement with Dual Academy Corp.

Affiliated and partner entities

We may share information with affiliated entities and educational partners for legitimate purposes related to your educational relationship with NewU, including transfer pathways and joint academic offerings.

Accreditation, government, and audits

We may share information with accrediting organizations, including the Middle States Commission on Higher Education, with state and federal education and licensing authorities, with agencies administering veterans education benefits where you have applied for those benefits, and with auditors, as required for program compliance, licensure, or reporting obligations.

Legal requirements

We may disclose information when required by law, subpoena, court order, regulatory authority, or to protect the rights, property, or safety of NewU, our users, or the public, including in a health or safety emergency.

Business transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

With your consent

We may share your information for other purposes when you give us explicit consent to do so.

Cookies and Tracking Technologies

We use cookies and similar technologies to operate our website, remember your preferences, analyze traffic, and improve your experience.

Types of cookies we use:

• Essential cookies. Required for the website to function, for example authentication and security.
• Functional cookies. Remember your preferences and settings.
• Analytics cookies. Help us understand how visitors use the site.
• Marketing cookies. Used to deliver relevant advertising on other sites. Under some state privacy laws this is treated as "sharing" personal information for cross-context behavioral advertising, and you may opt out as described below.

You can control cookies through your browser settings or through our cookie consent banner when you visit the site. Declining marketing cookies in the banner opts you out of cross-context behavioral advertising. Disabling certain cookies may affect website functionality.

Your Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

• Access. Request a copy of the personal information we hold about you.
• Correction. Request that we correct inaccurate or incomplete information.
• Deletion. Request that we delete your personal information, subject to legal exceptions.
• Opt out of marketing. Unsubscribe from emails using the link in every email, or text STOP to opt out of SMS.
• Opt out of sale or sharing. Where applicable under state law. NewU does not sell personal information. To opt out of sharing for cross-context behavioral advertising, decline marketing cookies in our cookie banner or write to us.
• Data portability. Request your information in a portable format.
• Non-discrimination. We will not discriminate against you for exercising your privacy rights.

To exercise any of these rights, contact us at [email protected]. We will respond within the time period required by applicable law, generally 45 days.

California Residents

California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the CPRA, including the rights described above and the right to know what categories of personal information we collect, use, and disclose.

Categories of personal information we collect

Identifiers (name, email, phone, IP address); customer records (contact, educational, and financial information); commercial information (services inquired about); internet activity (interactions with our website); audio and visual information (class recordings and, where used, proctoring recordings); professional or education information (transcripts, grades, and academic records); and inferences drawn from this information.

Categories of sources

Directly from you; automatically through your use of our website and learning platforms; from service providers; from dual enrollment partners and prior schools; and from publicly available sources.

Categories of recipients

Service providers, school officials, dual enrollment partners, affiliated and partner entities, accreditors, and government and regulatory authorities as required by law.

Where information forms part of a student education record, we handle the request under the Education Records, Class Recordings, and Proctoring section, and some records cannot be deleted because retention is required by law or by accreditation standards. To exercise your CCPA rights, contact us at [email protected].

Children's Privacy and Minor Students

Our website is not directed to children under 13, and we do not knowingly collect personal information from children under 13 without verifiable parental consent. If you believe a child under 13 has provided us with personal information without parental consent, contact us at [email protected] and we will take steps to delete that information.

For a person between 13 and 17 who contacts us directly, for example a prospective student still in high school, we collect the information voluntarily provided through our forms, and we ask that a parent or guardian review and consent to that correspondence.

Students under 18 enrolled in NewU classes

Some NewU classes enroll students under 18 through dual enrollment partners, including NewU Dual Academy. For those students, consent to enrollment and to class recording is obtained from the parent or legal guardian by the enrolling institution through its enrollment terms, which describe what is recorded, who may access it, and how long it is kept. The enrolling institution holds those consents and produces them to us on request.

A parent or legal guardian may contact us at [email protected] with any question about information we hold about their child, including what class recordings exist.

Data Security

We use reasonable administrative, technical, and physical safeguards to protect your personal information, including encryption in transit, access controls, role-based permissions on student records and recordings, and multi-factor authentication on accounts with access to student data. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

In the event of a breach affecting your information, we will notify you without unreasonable delay and in accordance with applicable law, and we will notify any affected dual enrollment partner as required by our agreement with it.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, comply with our legal, regulatory, and accreditation obligations, resolve disputes, and enforce our agreements. Specific retention periods are as follows.

• Academic transcripts and degree records. Retained permanently, because they may be needed to verify credentials throughout a graduate's lifetime.
• Other student education records. Retained for seven years after graduation or last attendance.
• Class recordings. Retained for one academic year and then deleted, as described in the Education Records, Class Recordings, and Proctoring section above.
• Proctoring recordings. Retained for no longer than one academic year and then deleted.
• Financial records. Retained for seven years, or longer where tax or audit obligations require it.

Where a record must be preserved for an investigation, a legal hold, an accreditation requirement, or as otherwise required by law, we retain it for as long as that requirement applies.

Governing Law

This Privacy Policy, and any dispute arising from or relating to it, is governed by the laws of the District of Columbia, without regard to conflict of laws principles. Any legal action or proceeding arising under this Policy shall be brought exclusively in the federal or state courts located in the District of Columbia, and the parties consent to the personal jurisdiction and venue of those courts.

Where you have accepted a NewU enrollment agreement, or where a dual enrollment partner's terms of enrollment apply to your class, the dispute resolution provisions of that agreement, including any internal grievance and arbitration provisions, apply to a dispute arising under this Policy.

Third-Party Links

Our website and learning platforms may contain links to third-party websites or embed third-party tools, for example a dual enrollment partner's portal or remote proctoring software. Where a third party processes student information on our behalf, it does so under a written agreement as described in the How We Share Your Information section. Where you follow a link to a site we do not control, we are not responsible for that site's privacy practices, and we encourage you to review its privacy policy before submitting personal information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we update the "Last updated" date at the top of this page. The version published here is the current version and replaces every earlier version, and a change takes effect when it is posted. Your continued use of the Service, or continued enrollment in a NewU class, after that date constitutes acceptance of the updated policy. We may also announce a significant change through the channels you already receive from us, but posting the revised policy on this page is the notice we give.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us:

For a question about a Dual Academy high school record, or about consent obtained by a dual enrollment partner, contact Dual Academy Corp. at [email protected]. The Dual Academy Privacy Policy is published at dualacademy.org/privacy.