Anthology Inc. of NY (f/k/a Campus Labs, Inc.) (“Anthology,” “we,” “us,” or, “our”) is a hosted constituent engagement portal which has been purchased for your exclusive use (“Services,” “System,” “Site,” or “Website”) by your affiliated college, university, institution, or other organization (“Client”). “You,” “Your,” “Constituent,” “Member,” or “User” is referring to an individual associated with the client, who visits or has access to any of our associated Websites or Services.
This Website may disclose personal information (see the Personal Information section) when required by law or in the good-faith belief that such action is necessary to conform to the edicts of the law or comply with a legal process involving the Website.
Collection and Use of your Personal Information
This Site requires your institution to provide your Personal Information which will be used to identify you or a User. Such information may include your: full name, address, email address, sex, city, state, country, and postal code (“Personal Information”). You may review and edit this information by contacting your institution. All data values are stored encrypted. Please note we do not support the collection or storage of any sensitive personal information relating to government issued identifications from you or our Clients on our Site (see the Personally Identifiable Information section for details).
Access to Personal Information
We provide Clients and their Constituents with reasonable access to an individual’s Personal Information maintained within our System. In addition to your ability to update Personal Information within your profile; you must contact your institution for inquiries to correct, amend, or delete inaccurate Personal Information. However, Anthology may deny access to Personal Information when providing such access is considered unreasonably burdensome, expensive, or as otherwise permitted under the Privacy Shield principles. See the Contacting the Website section for details on Clients and their Constituents resting access to an individual’s Personal Information.
Use and Disclosure of Personal Information
In support of our Clients, we collect demographic data, such as your first and last name, email address, and other contact information (postal address and telephone number) to authenticate and provide services that meet the Client’s objectives. Additionally, we will aggregate your Personal Information in an anonymous manner to compile statistical and performance information related to the operation of our System (“Aggregated Anonymous Data”). Anthology uses Aggregated Anonymous Data in order to create product and Service enhancements; provided, that such information does not incorporate any of our Client’s data, your Personal Information, or additional data you and our Clients provide. Our use of your Personal Information and Aggregated Anonymous Data is strictly limited to the extent necessary to perform the Services for our Clients. This includes Anthology, our parent, subsidiaries, affiliates, and service providers.
EU and Swiss individuals have rights to access their Personal Information, and limit use and disclosure such Personal Information. Unless authorized by you; we will not use or disclose your Personal Information or other data identifiable to you that are outside the original intent necessary for our Site. As noted in the Access Personal Information Section above; individuals have the ability request access, limit our use or disclosure (opt out) through your institution. We will work with your Institution for any individual inquiry or opt out request received. Additionally, we may disclose your Personal Information if we are required to do so under applicable law, public authorities, enforceable government request, meet national security, or when we believe disclosure is necessary to prevent harm or financial loss or in connection with suspected or actual illegal activity.
As noted in our Personally Identifiable Information section below, Anthology does not collect sensitive personal information; including, but not limited to, government issued identifications, medical or health conditions, political opinions, religious or philosophical beliefs, trade union membership or other sensitive information as defined by the Privacy Shield framework.
Use of Google APIs
Some of Anthology’s products make it easier to work with Google APIs, specifically, Google Drive. If applicable and provided by the Client, Constituents can connect to Google Drive in order to copy over individual files for use within their coursework. Anthology does not access data within Google Drive except when explicitly directed by the Client on the Constituent’s behalf. Any files that are copied from Google Drive within Anthology’s platform remains hosted until deleted by an authorized party, or until the Client terminated this service.
Use of our Site and Services
This Site cannot guarantee the accuracy of information presented. However, anyone demonstrated to have engaged in fraudulent behavior may be subject to (but not limited to) loss of privileges as a member as well as face prosecution to the fullest extent of the law.
Photo, Blog, and other Personal Content Policy
This Site retains the right to remove or reject any content that it deems obscene or objectionable or has been reported as such by other members. In addition, the Client licensors of the Website can at any time deem content to be objectionable and can remove or request it be removed from the Site. This Site does not endorse any user generated content that is posted on the Site. Members will not post copyrighted content without permission from the owner. Members understand content — whether it be text, graphic, or audio visual — is the sole responsibility of the person from which such content originated. This Site is no way responsible for the accuracy, integrity, or quality of such content.
Links to Other Sites
This Site may contain links to other sites. This Site is not responsible for the privacy practices or the content of such websites.
Compliance and Security
Anthology treats the security of our Clients’ data and Constituent data with utmost importance. We take many precautions at the infrastructure and software layers to deliver the highest level of protection for your Personal Information and other additional Constituent data provided by you or our Clients. Anthology owns and operates the database and web servers that host Clients' websites and, stores Client and Constituent data, including your Personal Information. These servers are protected by securely configured firewalls that prevent data from being accessed via the Internet. Each of our Client's data, Personal Information, and other additional Constituent data are stored in a dedicated database; this prevents the intrusion or corruption of data. In addition, our Clients' data catalogs cannot see or access each other's data.
Measures have been taken to make transactions secure for Members on our Sites and transaction pages. Login, and administrative activity are transmitted over an industry standard Secure Socket Layer (“SSL”). All transactions encrypt your Personal Information to prevent unauthorized access as the information travels over the Internet.
Logins and Passwords
Strong passwords are required for each login, and they are stored in a format that cannot be read by administrators or employees. Multiple failed logins or lost login requests are challenged by reCaptcha. An administrative rights system restricts authenticated but unauthorized access to Constituent data.
Anthology connects to Clients’ authentication systems in order to identify and credential users. This means that the client logs in using their campus username and password. The centerpiece of each method is a secure transmission of a unique identifier for a user upon a successful granting of credentials. Some of the supported protocols also allow for the passing of additional attributes from a directory or other campus system.
Personally Identifiable Information (PII)
Anthology does not encourage the collection, storage, or display of sensitive personal information or personally identifiable information in our System or use of our Services. We define “Personally Identifiable Information” or “PII” as information which includes: (i) Non-Public Directory information as defined by the Family Educational Rights and Privacy Act (FERPA); (ii) Health Insurance Portability and Accountability Act (HIPAA); or (iii) government issued identifications, including, but not limited to, Social Security Numbers, Driver License Numbers, and Individual Taxpayer Identification Numbers.
As part of our company policy, we maintain confidentiality and security features consistent with commercially reasonable industry standards which are appropriate to protect our System, as well as any data provided by you and our Clients. To the extent Personal Information or other additional Constituent information you provide is stored in our System, such information is treated as confidential information by Anthology.
Our security standards and data protection cover the data entered and maintained within the system. Client’s authorized administrators are also required to follow proper guidelines and standards in the use of the data and our Services to prevent unintended access of all data we maintain within our System. Accordingly, we offer our Clients comprehensive product training which includes setup and configuration of the Site, as well as ongoing product support, for purposes of ensuring Clients adhere to our confidentiality standards and proper use of our System. However, Clients are responsible for process and procedures to ensure the proper use of our Services, including data provided by you and our Clients comply with all applicable governing laws related to your Personal Information and confidentiality.
In compliance with the Privacy Shield Principles, Anthology commits to resolve complaints about our collection or use of your Personal Information. EU and Swiss individuals should first contact Anthology with inquiries or complaints regarding the Privacy Shield policy (see the Contacting the Website section below). Anthology has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland. If Anthology fails to respond within a reasonable time, or if our response does not address your concerns, you may contact the EU DPA’s or FDPIC, as applicable, for more information or to file a complaint. The services of the EU DPA’s or FDPIC are provided at no cost to you.
As a final point, Anthology commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).
California Consumer Privacy Act (CCPA)
If in the rare instance the iModules hosted site you are visiting is outside of the non-profit or higher education industry and if you reside in California, then you have the following rights:
- You have the right to request the deletion of your personal information.
General Inquiry and Other Policy Items
Contacting the Website
If you have any questions about this privacy statement, the practices of this Site, or your dealings with this Website, please contact Customer Support at firstname.lastname@example.org or (716) 270-0000.
Last updated August 1, 2020