Last Updated: December 19, 2019
I. COLLECTION OF INFORMATION
A. Information You Provide
We may obtain information that you provide directly to us on the Sites and this includes, without limitation, all online and offline collections of all types of personal information, for example when you create an account, enter a sweepstakes on the Sites or on a third-party site, sign up for email communications, participate in a survey, contact customer service, engage in a promotion online or instore, or otherwise interact with the Sites. This information may include personal information, which is information that can be used to identify you individually. Personal information collected may include:
? Contact information, such as name, address, email, telephone number, fax number, organization name, and/or job title
? Unique identifiers and preference information such as username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, or navigation and clickstream behavior for online interactions
? Resume including work history, professional qualifications, publications, awards, references, completed trainings, signature
? Food restrictions, passport info for travel bookings or identification purposes, social security number (where required by law), bank account details, (emergency) contact persons, family information (where applicable and in accordance with local law)
? Creditworthiness, VAT number, product, purchase information history, request documentation
? Pictures, video and audio recordings where you have provided your permission
? Sensitive personal information, such as health information or reports of an individual end-customer, i.e. concerning product claims and investigations, patient pre- and post-operative outcomes for research & statistical purposes, or criminal records for due diligence procedures in accordance with applicable law
Kellogg Company will retain and use the personal information collected for the above-mentioned processes and processing purposes in accordance with its obligations, including but not limited to legal, business and administrative obligations. Kellogg Company may also collect product and service information and provide these statistics to others in an aggregate form where the information has been de-identified.
B. Information Collected Automatically
The Site is a general audience web site. In addition to any Personal Information or other information that you choose to submit to the Site, we and our third-party service providers, including any third-party content, advertising, and analytics providers, may use a variety of technologies that automatically or passively collect certain information about your use of the Site whenever you visit or interact with the Site (“Site Usage Information”). Site Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that led you to our Site (if applicable), actions you take on the Site and all of the areas within our Site that you visit, and the time of day you visited the Site, among other information. Site Usage Information may also include the unique IP address or other unique identifiers (“Device Identifier”) for any computer, mobile phone, or other device (any, a “Device”) used to access the Sites. A Device Identifier is a unique value that is automatically assigned to your Device, so that our servers can identify your Device by its Device Identifier.
We may use Site Usage Information for a variety of purposes, including enhancing or otherwise improving the Sites and our products and services. We may associate Site Usage Information with you as a specific and identifiable person. When we do so, we treat the combined information as personal information.
The types of information we collect automatically when you visit the Sites may include IP addresses, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visit, and pages viewed. We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from third parties. Information about your use of the Sites and other websites may be collected across time, devices, and websites for various purposes, including to associate different devices you use and to deliver relevant and/or retargeted content. If you choose not to provide the personal information we reasonably require, it may hinder Kellogg Company’s ability to provide the information or services you have requested.
II. USE OF INFORMATION
We may use certain third-party web analytics services, such as Google Analytics, to help us understand and analyze how visitors use the Sites and serve ads on our behalf across the Internet. For example, if you clicked on one of our advertisements that led you to the Site, our service provider(s) may be able to tell us information about your interaction, such as, but not limited to: which advertisement you clicked on, where you were viewing the advertisement, how often you viewed or clicked on it, and so forth. In connection with serving content and providing analytics and advertisement services, third parties may collect certain information about your visits to the Sites or other websites. Some of these parties may collect personal information when you visit the Sites or other websites or services. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your Device Identifier, Site Usage Information, and related information about you. Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, and to conduct research regarding the usefulness of certain advertisements to you. We may share Device Identifier and Site Usage Information about visitors with third-party advertising companies, analytics providers, and other vendors for similar purposes.
III. DISCLOSURE OF INFORMATION
Certain content on the Sites may be hosted and served by third parties and the Sites may contain links to third-party websites that Kellogg Company does not control. The Site may also contain certain third-party content or applications. These links and applications may use a Kellogg Company logo as part of a co-branding agreement. In addition, Kellogg Company widgets or other Kellogg Company content may be included on web pages and websites that are not associated with Kellogg Company and over which we have no control. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. Kellogg Company is not responsible for the privacy practices employed by any third party.
Kellogg Company may share information, including personal information, as applicable, among its subsidiaries and affiliates, primarily for business and operational purposes. Kellogg Company may also disclose and transfer your information, including Personal Information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) if Kellogg Company (or any of its affiliated subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of our ownership interests, assets, or both, or other corporate change, including, without limitation, during the course of any due diligence process.
We may use third party service providers to help us operate our business and the Sites or administer activities on our behalf. We may share information with third parties so that they may provide services to you, Kellogg Company, and the Sites. Examples include conducting website usage analysis, sending e-mail or other communications on our behalf, providing sales and marketing assistance, or performing other administrative or support services. For instance, if you participate in a sweepstake, game, or loyalty program resulting in a prize or award, we will share your information with our games and merchandise fulfillment and management agencies. When we do so, the information is only to be used to provide services or help us provide services. Third-party systems used to deliver services to you may retain your information for a period of time after the services are provided.
Personal information of any individual user may be shared with other companies outside Kellogg Company: (i) as permitted by law; (ii) in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions; (iii) where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; or (iv) to enforce our policies, or to protect legal rights, propriety, or safety. (v) to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation (including to meet national security or law enforcement requirements); (iii) to enforce applicable Sites terms and policies; or (iv) to respond to an emergency or otherwise to protect the safety, rights, property, or security of Kellogg Company, third parties, Site visitors, or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with a court order or law enforcement agencies when legally compelled to do so.
IV. USER-GENERATED CONTENT FUNCTIONS
If you submit User Generated Content, it may be published online or offline (including on the Site, on-air, in a DVD, or any other format currently existing or later developed). In addition, we may use your User Generated Content and any excerpt from your User Generated Content in connection with our advertising, marketing, publicity, and promotional activities, and you hereby grant us a worldwide, perpetual, royalty-free, fully paid right and license to copy, display, distribute, modify and publicly perform, as applicable, the User Generated Content for such purposes. However, Kellogg will not publish your e-mail address with these comments. Please note that we do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Sites or what others do with information you share with them on the Sites. We are not responsible for the accuracy, use, or misuse of any User-Generated Content that you disclose or receive from third parties through the Sites.
V. SWEEPSTAKES, CONTESTS ETC.
VI. LINKS AND THIRD PARTIES' PRIVACY PRACTICES
We may also receive information about you from third parties. For example, if you are on another website that provides information about service providers like Kellogg Company and you request to receive information from Kellogg Company that website will forward your contact and other information to us so that we may contact you as requested. Third parties may also provide information about you in connection with a marketing arrangement we may have with those third parties.
You can correct, make changes, update or otherwise modify some of the personal information you have provided to us several ways. If you are a customer, you can update your personal information (including opting out) by logging into any feature provided by the Site’s platform and changing your profile in the system or use the Contact Us form on the Sites. You may also contact us via telephone at 800-962-1413 and request that we change your information. Kellogg Company also gives you convenient methods for removing your information from our database so as not to receive future communications or to close your account via any of the methods detailed herein. You may also send mail to the following postal address:
Attn: Consumer Affairs
PO BOX CAMB
Battle Creek, MI 49016
You may request details of personal data which we hold about you. If you believe that any personal information we are holding about you is incorrect, incomplete, you would like to object to the collection or use of your information, or you would like to have your information erased, please contact us as soon as possible, at the address above. We will promptly correct any personal information found to be incorrect.
IX. CHILDREN’S PRIVACY
Our Sites are not intended for, nor targeted to, children under 13, and we do not knowingly request or collect personal information from any person under 13 years of age through the Sites. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law. Kellogg Company will not collect personal information from anyone we know to be under the age of 13 without the prior, verifiable consent from his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.
X. APPLYING FOR A JOB THROUGH OUR SITE
If you apply for a job through the Site, we, or a human resources company assisting us, may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”), and similar state and local regulatory agencies. Providing self-identifying information is voluntary, but if you do provide us with that information, we may submit it to the EEOC, the OFCCP, and similar state and local regulatory agencies for business-related purposes, including responding to information requests, fulfilling regulatory reporting requirements, and defending against employment related complaints.
XI. NEVADA PRIVACY RIGHTS
XII. INFORMATION FOR USERS OUTSIDE THE UNITED STATES
To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to Kellogg Company affiliates, subsidiaries or business partners in other countries, including in the United States, different standards may apply to how your data is used and protected in those countries. Kellogg Company has appropriate safeguards in place in accordance with applicable legal requirements to ensure that data is adequately protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by Kellogg Company and standardized corporate safeguards and contractual measures (based on the European Commission Model Clauses) for internal data transfers to Kellogg Company affiliates in third countries which are deemed to provide an inadequate level of data protection.
XIV. CONTACTING KELLOGG COMPANY
Phone: 800-962-1413 (9am-6pm ET)
Website: Contact Us
Postal Address: Kellogg Company
Attn: Consumer Affairs
PO BOX CAMB
Battle Creek, MI 49016
PRIVACY STATEMENT FOR CALIFORNIA
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
- Job applicants, current and former employees and independent contractors
- Representatives of another business in connection with business communications or transactions
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our consumers or their agents. For example, through consumers provide to us related to the services or products for which they engage us.
- Indirectly from our consumers or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.kelloggs.com). For example, from submissions through our website portal or website usage details collected automatically.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us information to purchase a product or service, we will use that information to process that order and facilitate delivery. If you provide us information to participate in a sweepstakes or promotion, we will use that information for your participation.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, as applicable.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our customers, consumers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
|Category B:||California Customer Records personal information categories.|
|Category C:||Protected classification characteristics under California or federal law.|
|Category D:||Commercial Information.|
|Category F:||Internet or other similar network activity.|
|Category G:||Physical location or movements.|
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates, subsidiaries and affiliated brands.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information for a third party’s commercial purpose or for monetary value however we do disclose personal information for internal business purposes.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, unless an exception applies, we will delete (and direct our service providers to delete) your personal information from our records.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Visiting www.privacy.kelloggcompany.com
- Calling us at 800-962-1413
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
California’s “Shine the Light” Law
California law permits customers in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates, if the personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request and obtain from us once a year, free of charge, information about the personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year.
To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify “California Shine the Light Privacy Rights Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
Removal of Content Posted by Minors
California residents under the age of eighteen (18) who have registered to use the Sites, and who have posted content or information on the Sites, can request that such information be removed from our Sites by contacting us, stating that they personally posted such content or information and detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. However, this removal process cannot ensure complete or comprehensive deletion from the Internet. For instance, third parties may have republished the post and/or archived copies of it may be stored by search engines or other parties that we do not control.
Changes to Our Privacy Notice
If you have any questions or comments about this privacy notice, please contact us at firstname.lastname@example.org. If you have any questions or comments regarding the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us at:
Phone: 800-962-1413 (9am-6pm ET)
Website: Contact Us
Postal Address: Kellogg Company
Attn: Consumer Affairs
PO BOX CAMB
Battle Creek, MI 49016