Anthology Trust Center

U.S. State Privacy Notice

Last updated: December 27, 2022

Summary

Our Commitment to Privacy

We care about privacy. We believe that privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of their employees and their users, who are often students. We take the obligations that are attached to this information very seriously. We therefore have a dedicated data privacy program with privacy by design at heart. You can learn more about our data privacy program by visiting our Trust Center.

Scope of Notice

For residents of the States of California, Colorado, Connecticut, Nevada, Utah and Virginia ("consumers" or "you"): This U.S. State Privacy Notice (the “Notice”) supplements the information in our Privacy Statement and provides additional information about our personal information processing practices relating to individual residents of these states.

This Notice only reflects how we collect, use, disclose, and otherwise process personal information for our own purposes (e.g., for our websites and marketing) and are acting as a ‘business’ or ‘controller’. Where we provide our products and services to consumers on behalf of our clients, we are acting as a ‘service provider’ or ‘processor’ and process personal information under the terms of a contract with our institutional clients. In this case, the client’s privacy notice governs the use of personal information and the rights and choices the client’s end users may have with regard to their personal information. For example, when we process Student Data on behalf of our client institution, we are acting as a service provider, or a “School Official” under FERPA, and we retain, use, and disclose the Student Data in accordance with our written agreement with the client.

For the purposes of this Notice, personal information does not include:

  • Publicly available information from government records
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you
  • Information relating to our employees, contractors, and other personnel (which is governed by a separate privacy notice)

Any terms we use in this Notice that aren’t defined in this Notice or our Privacy Statement will have the same meaning as in the applicable state data protection laws.

Personal Information Collection and Use

As described in more detail in the How we use your information depends on your relationship with us section of our Privacy Statement, we collect the following categories of personal information:

Category of Personal Information Collected Sources of Information
Identifiers, such as your name, customer number, address, phone number, email address, date of birth or other similar identifiers.
  • Directly from you
  • From your institution
  • Our business partners
Customer Records such as contact information, payment information
  • Directly from you
  • From your institution
  • Our business partners
Protected Classification Characteristics, such as age or disability (if provided for accommodation purposes)
  • Directly from you
Commercial Information related to the products that you or your institution have purchased or intend to purchase
  • Directly from you
  • From your institution
  • Your browser or device
Internet/Network Information, such as device information, IP address, logs and analytics data
  • Your browser or device
Geolocation Data, such as precise location information from your device or rough location generated based on IP address
  • Your browser or device
Sensory Information, such as recordings of phone calls with us, where permitted by law
  • Directly from you
Profession/Employment Information, such as the institution you are affiliated with and your role in the organization
  • Directly from you

  • From your institution

  • Our business partners and affiliates

Other Personal Information that may be contained in online chat, document uploads, and user-generated content
  • Directly from you

  • Your browser or device

Inferences about your interests and preferences generated or derived from your usage of our products or services
  • Directly from you

  • Your browser or device

Purposes for Collection

We collect personal information from and about you for the purposes described in detail in the How we use your information depends on your relationship with us section of our Privacy Statement. For example, we use personal information to fulfill or meet the reason you provided the information, to communicate with you, to operate, maintain, and provide to you the features and functionality of our websites (e.g., anthology.com), to market to you, for testing, research, analysis, and product development, including to develop and improve our services, and for any other business and operational purpose described in our Privacy Statement and as otherwise permitted or required by law.

Sensitive Information

Some of the categories of personal information we collect may be classified as “sensitive” under certain U.S. state privacy laws (“sensitive information”), including, health and disability information (e.g., to allow us to appropriately accommodate the needs of representatives of our clients who attend our conferences). We use this sensitive information only for the purposes described in our Privacy Statement or as disclosed at the time of collection, the extent necessary to operate and provide our products and services, to enter into and perform a contract with you, to comply with legal and regulatory requirements or as otherwise permissible for our own internal purposes consistent with laws.

The categories of third parties to whom we have disclosed personal information for a business purpose include:

Deidentified Information

We may at times receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Personal Information Disclosure, Sale and Use for Targeted Advertising

Disclosure

As described in more detail in the How we use your information depends on your relationship with us section of our Privacy Statement, we may disclose the categories of personal information identified above to the following categories of third parties for various business purposes: our affiliates and subsidiaries, our vendors and service providers, analytics providers, security providers, other businesses as needed to provide our products and services, our business partners and third parties at your request. From time to time, we may also disclose personal information to third parties for other purposes, such as if reasonably necessary to comply with law or a legal or contractual obligation, or in the context of a corporate transaction. Please see our Privacy Statement to learn more.

Sales and Targeted Advertising

We do not sell your personal information for profit. However, we do engage in targeted advertising on our own websites (but not in our products), which may be considered a “sale” under certain state data protection laws. In this context, As is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, location data, and inferences generated from your browsing history and interactions with our services as well as other sites and services. These third parties use this personal information to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our websites, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. To learn more, please see our Cookie Statement.

We do not sell the personal information of consumers we know to be less than 16 years of age or use or share such information for targeted advertising purposes.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising (as described in the Your Privacy Rights section below).

Your Privacy Rights

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following privacy rights.

Please remember: If you are a user of our products and services that we provide on behalf of your institution, you must contact your institution to exercise your rights. They need to manage your request even if it relates to information that we store on behalf of your institution. We will support your institution as needed with your request.

The Right to Know

You have the right to confirm whether we are processing personal information about you, and under California law only, to obtain certain details about the personal information we have collected about you, including:

  • The categories of personal information we have collected;

  • The categories of sources of the personal information;

  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

  • The categories of personal information shared for targeted or cross-contextual advertising purposes (if any), and the categories of recipients to whom the personal information was disclosed; and

  • The categories of personal information we have sold and the categories of third parties to whom the information was sold.

The Right to Access & Portability You have the right to access the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity.
The Right to Correction You have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The Right of Control over Sensitive Information

You have the right to exercise control over our collection and processing of certain sensitive information.

The Right to Request Deletion

You have the right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Data Sales

You have the right to direct us not to sell personal information we have collected about you to third parties.

The Right to Opt Out of Sharing for Targeted Advertising

You have the right to direct us not to use or share personal information for targeted advertising or cross-context behavioral advertising purposes.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if exercising these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our services or engage with you in the same manner.

To Submit Your Privacy Rights Request

You may submit a request to exercise your privacy rights through one of the mechanisms described below. We will need to verify your identity before processing most requests, which may require us to obtain additional personal information from you or require you to log into your account, if you have one. We will only use such personal information to review and comply with your request. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate information in our systems, or as permitted by law.

To exercise your privacy rights, please submit a request by:

  • Filing out our U.S. Resident Privacy Rights Request Form, or
  • Emailing privacy@anthology.com with the subject line “U.S. Privacy Rights Request,”
  • Alternately, California consumers may submit a request by calling 877-918-2620 (Please note, response times may be faster if you submit your request through our U.S. Resident Privacy Rights Request Form above or via email)

To exercise your right to opt out of Targeted Advertising, please visit our Cookie Preferences Center to set your preferences for cookies used for targeted advertising. Please note this opt out is browser specific and you must reset your preferences if you clear cookies or use a different browser or device.

Please also refer to our Cookie Statement to learn more about how third party ad networks, social media companies and other third party businesses collect information from you when you visit our websites and the opt-out choices you may have in relation to those activities.

Authorized Agents

In certain circumstances, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney. For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the individual on whose behalf the request was made.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to privacy@anthology.com.

Updates to this Notice. We will update this Notice from time to time. When we make changes to this Notice, we will change the "Last Updated" date at the beginning of this Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

You can contact us at privacy@anthology.com and can find our additional contact details in our Privacy Statement.