WK Kellogg Co California Applicant Privacy Notice

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Last Updated: August 28, 2023

WK Kellogg Co, our subsidiaries, and our affiliates (collectively, “WKKC”) provides this California Applicant Privacy Notice (“Notice”) to explain our practices regarding the Personal Information we collect about individuals in our job application process, including our careers websites (“Applicants”). This Notice explains what Personal Information we collect about California Applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”).

In the event of a conflict between any other policy, notice, or statement and this Notice, this Notice will control as to California Applicants.

1. PERSONAL INFORMATION WE COLLECT, USE, AND DISCLOSE FOR BUSINESS PURPOSES

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

We collect, use, and/or disclose and, within the past twelve (12) months, may have collected, used, and/or disclosed the following categories of Personal Information about California Applicants, as described below.  Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all the examples listed below.

Identifiers

Category of Personal Information

Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, passport number, or other similar identifiers

Categories of Sources and Purposes for Collection and Use

Sources

Directly from you
Automatically when you use our website
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To open and maintain your application records
To assess your eligibility for employment
To communicate with you regarding your application
To comply with applicable laws and regulations
To manage the security of our premises and systems
To detect and prevent fraud against you and/or us
To manage the security of our premises and systems
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business
Governmental authorities

Business Purposes for Disclosure

To ensure security and integrity of Personal Information
To debug to identify and repair errors that impair existing intended functionality
For short-term, transient use
To perform services on our behalf
To undertake internal research for technological development and demonstration
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Personal Information described in Cal. Civ. Code § 1798.80(e)

Category of Personal Information

Personal Information described in Cal. Civ. Code § 1798.80(e), including name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, and employment history

Categories of sources and Purposes for Collection and Use

Sources

Directly from you
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To open and maintain your application records
To assess your eligibility for employment
To communicate with you regarding your application
To comply with applicable laws and regulations
To manage the security of our premises and systems
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purpose for Disclosure

Recipients

Service providers that help us to run our business
Governmental authorities

Business Purposes for Disclosure

To ensure security and integrity of Personal Information
To debug to identify and repair errors that impair existing intended functionality
For short-term, transient use
To perform services on our behalf
To undertake internal research for technological development and demonstration
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Characteristics of protected classifications

Category of Personal Information

Characteristics of protected classifications  under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability

Categories of Sources and Purposes for Collection and Use

Sources

Directly from you
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To comply with applicable laws and regulations

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business
Governmental authorities

Business Purposes for Disclosure

To ensure security and integrity of Personal Information
For short-term, transient use
To perform services on our behalf
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity

Internet or other electronic network activity information

Category of Personal Information

Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements

Categories of Sources and Purposes for Collection and Use

Sources

Automatically when you use our website
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To facilitate your use of our website
To provide you with tailored recommendations, and updates
To improve our website, set default options, and provide you with a better application experience
To protect the security of our website
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business

Business Purposes for Disclosure

To ensure security and integrity of Personal Information
To debug to identify and repair errors that impair existing intended functionality
For short-term, transient use
To perform services on our behalf
To undertake internal research for technological development and demonstration
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Geolocation data

Category of Personal Information

Geolocation data, including location data inferred from your device IP address

Categories of Sources and Purposes for Collection and Use

Sources

Automatically when you use our website
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To provide you with tailored recommendations, and updates
To show you relevant ads while you are browsing the internet or using social media
To improve our website, set default options, and provide you with a better application experience
To protect the security of our website
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business

Business Purposes for Disclosure

To ensure security and integrity of Personal Information
To debug to identify and repair errors that impair existing intended functionality
For short-term, transient use
To perform services on our behalf
To undertake internal research for technological development and demonstration
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Audio, electronic, visual, thermal, olfactory, or similar information

Category of Personal Information

Audio, electronic, visual, thermal, olfactory, or similar information, including closed-circuit images, photographs and video of you, and audio recordings as may relate to your application

Categories of Sources and Purposes for Collection and Use

Sources

Directly from you
Automatically while you are on WKKC property

Purposes for Collection and Use

To manage the security of our premises and systems

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business

Business Purposes for Disclosure

To perform services on our behalf
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Category of Personal Information

Professional or employment-related information, including:

Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;
Answers to behavioral or other screening questions in an application or interview;
Information contained in any personal webpages or documents you choose to share with us;
Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations;
Information relating to membership in civic organizations

Categories of Sources and Purposes for Collection and Use

Sources

Directly from you
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To open and maintain your application records
To assess your eligibility for employment
To comply with applicable laws and regulations
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business
Governmental authorities

Business Purposes for Disclosure

To perform services on our behalf
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provide

Non-public education information

Category of Personal Information

Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education

Categories of Sources and Purposes for Collection and Use

Sources

Directly from you
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To open and maintain your application records
To assess your eligibility for employment
To comply with applicable laws and regulations

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business

Business Purposes for Disclosure

To perform services on our behalf
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Inferences

Category of Personal Information

Inferences  used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Categories of Sources and Purposes for Collection and Use

Sources

Drawn from the other categories of Personal Information we collect

Purposes for Collection and Use

To assess your eligibility for employment
To manage the security of our premises and systems
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business

Business Purposes for Disclosure

To perform services on our behalf
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity
For internal use by the service provider

Sensitive Personal Information

Category of Personal Information

Sensitive Personal Information, including:

Social security, driver’s license, state identification card, or passport number
Account log-in, in combination with any required security or access code, password, or credentials allowing access to an account
Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership
Personal Information collected and analyzed concerning a consumer’s health (i.e., drug-screening information)
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation

Categories of Sources and Purposes for Collection and Use

Sources

Directly from you
From service providers that help us to run our business
From third parties

Purposes for Collection and Use

To open and maintain your application records
To assess your eligibility for employment
To comply with applicable laws and regulations
To manage the security of our premises and systems
To detect and prevent fraud against you and/or us

Categories of Recipients and Business Purposes for Disclosure

Recipients

Service providers that help us to run our business
Governmental authorities

Business Purposes for Disclosure

To ensure security and integrity of Personal Information
To perform services on our behalf
To process, maintain, or collect Personal Information on our behalf
To detect or protect against malicious, deceptive, fraudulent or illegal activity

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We collect the following information about you, which does not directly fall within the categories listed in the CCPA:

Citizenship, immigration, visa status, and work authorization information (including information from related documents, such as your passport, driver’s license, or other identification, proof of residence, and proof of authorization to work in the United States, and documents you provide with your US Citizenship and Immigration Services Form I-9)
Languages spoken
Criminal records information including results of background checks obtained through government agencies such as the US Federal Bureau of Investigation
Drug screening information
Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Professional or Employment-Related Information.

We do not use or disclose Applicant Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

How Long We Keep Your Personal Information

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
We are otherwise required or permitted to keep your information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

2. HOW WE SHARE AND SELL PERSONAL INFORMATION

We do not sell or share for cross-context behavioral advertising, and within the past twelve (12) months, have not sold or shared for cross-context behavioral advertising the Personal Information of California residents that we collect in relation to applications for employment at Kellogg. If you also interact with us as a consumer, please review our California Consumer Privacy Notice for more information about our practices in that context. We do not have actual knowledge that we sell or share the Personal Information of consumers or Applicants under 16 years of age.

3. SUBMITTING REQUESTS RELATING TO YOUR PERSONAL INFORMATION

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through our Privacy Portal or call us at 800-962-1413. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to provide a name, email address, and a government ID that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using our Privacy Portal or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

(1)   The categories of Personal Information we have collected about you, including

a.     The categories of sources from which the Personal Information was collected.
b.     Our business or commercial purposes for collecting or disclosing Personal Information.
c.     The categories of recipients to which we disclose Personal Information.
d.     The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

(2)   The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Inaccurate Information. If you believe the Personal Information we maintain about you is inaccurate, you have the right to request that we correct such information.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we may use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

4. HOW TO CONTACT US

If you have any questions about how we handle your Personal Information, please contact us at:

Email: HRDataPrivacy@wkkellogg.com

Phone: 800-962-1413 (9a.m.-6p.m. ET)

Postal Address:  WK Kellogg Co, Attention: Consumer Affairs – Privacy Office, 1 Kellogg Sq, Battle Creek, MI 49016