WK KELLOGG CO PRIVACY NOTICE

1. INFORMATION YOU PROVIDE

You may submit to us or we may obtain from other sources (e.g., customer service providers, marketing firms, data resellers, government entities, vendors or external parties providing Sites features) information about you, such as:

• Contact Information.   You may provide us your name, address, email, telephone number, fax number, organization name, job title, age, date of birth, or gender.
• Account and Profile Information.   If you register an account and create a profile, you may provide information such as your name, age, date of birth, gender, address, email address, and username/password.
• Loyalty Program Information.   If you sign up and participate in a loyalty program, you may provide your name, account information, contact information, purchase history, and coupon history.
• User Generated Content and User Interactions.  You may upload or submit user-generated content such as writings, posts, reviews, photos or videos you create.
• Identifiers.  We may collect identifiers such as online identifiers, Internet Protocol address, marketing identifiers, device identifiers, or other similar unique identifiers.
• Promotion or Voluntary Study Participation Information.  You may upload or submit information to participate in a promotion or voluntary study, such as your name, email, address, and other relevant information required by the promotion or study such as pictures, food restrictions, and purchase history.
• Payment Information.   You may provide certain payment information, such as credit card or other payment method information, as well as billing address information.
• Job Applicant Information.  You may be able to submit resumes, work history, professional qualifications, publications, awards, and references. You may also provide certain information such as veteran status, gender, and ethnicity, or other information in conjunction with laws and regulations (such as those enforced by the U.S.  Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”), and similar state, provincial, and local regulatory agencies), depending on your jurisdiction.
• Personnel Records.  If you are an employee, we may collect your signature, education, employment, and employment history.
• Commercial Information.  We may collect records of products or services purchased, obtained, or considered through the Sites as well as purchasing or consuming histories or tendencies, including coupon history.
• Internet or Other Similar Network Activity.   We may obtain your usage of the Sites or information that is necessary for the proper functioning or improvement of the Sites, such as:  (i) times and dates and the extent of your usage; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Sites; (iii) search terms related to Sites; (iv) the URL or advertisement that may have referred you to the Sites; and (v) other information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token.
• Location Data.   You may provide your location to obtain location-specific content, such as store locations.
• External Service Information.   We may obtain information about you from external services, such as where you choose to use a Sites feature provided by an external party. For example, when you use a social media account to register or log into an account, we may collect information about you in connection with social networking services (e.g., your public profile, friend list, people you follow or who follow you, your email address, birthday, work history, education history, interests, current city, website, personal description and likes, and your friends’ birthdays, education histories, personal descriptions and likes). We may also supplement certain information that we collect from you with outside records. External parties may provide us with information about you in connection with a co-marketing agreement or in connection with a tracking technology.
• Certain Characteristics.  You may provide us information about characteristics requiring certain protections. For example, we may collect ethnicity or national origin.
• Customer Support.  We collect information that you provide to us, including any personal information, when you contact us for customer-support purposes.
• Inferences Drawn From Other Personal Information.  We may make inferences about you based on other personal information we collect, such as your preferences and characteristics, including what products you may prefer we suggest to you.

We may supplement the information we collect with outside records from external parties. We may combine the information we receive from those other outside sources with information we collect through the Sites. In those cases, we will apply this Privacy Notice to the combined information.

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2.  TRACKING TECHNOLOGIES

In addition to any personal information or other information that you choose to submit through the Sites, we and our vendors may use a variety of tracking technologies, including cookies, that passively collect certain information whenever you interact with the Sites.  This type of usage information may include the device you are using, your IP address, device ID, anonymous traffic data, other unique identifier, location, all of the areas within our Sites that you visit, what content you are interested in or interact with, and the time of the visit.

Types of tracking technologies we may use:

• Functional, Necessary, and Performance:  To provide functionality to the Sites and help us deliver our products and services. For example, to help us route traffic between servers, retain user preferences, allow account log ins, and understand how the Sites are functioning.
• Analytics and Research:  To understand, improve, and research features and content on the Sites, including how users use the Sites and the content and products that users view most frequently.
• Social Media:  To provide features related to social media services, such as to enable you to share our content with your friends and networks. These tracking technologies are capable of understanding your interests and may impact content you see on social media services.
• Location:  We may use location-aware technologies to locate you, including as determined by your IP address, for purposes such as verifying your location and delivering or restricting content based on your location. Our Sites may be personalized to provide you with more location-relevant content.
• Security:  To enable security features and allow us to detect activity that might violate our rules and Terms of Use, such as unauthorized access or activity.
• Marketing and Online Behavioral Advertising:  We may use tracking technologies to provide advertisements on external-party online services. Certain external parties may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt-out of certain interest-based ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/ . Please be aware that, even if you are able to opt-out of certain kinds of interest-based ads, you will continue to receive non-targeted ads. We are not responsible for the effectiveness of, or compliance with, external parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

The Sites may enable you to change your preferences in relation to tracking technologies, including opting out of some or all of them, subject to applicable law and what tracking technologies may be necessary to enable the Sites’ functionality.

Some tracking technologies, have their own preference settings hosted on their own external online service.

We’ve implemented Google Analytics Advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and video ads reporting. We and our vendors may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to deliver advertisements, create a profile of you, measure your interests, detect your demographics, detect your location, detect your device, and personalize content. For more information on how Google Analytics uses data collected through the Sites, visit:  www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.

To opt out of Adobe cookies, visit: https://www.adobe.com/privacy/opt-out.html.

You may be able to opt out of social media tracking technologies through your social media account. For example, you may opt out of Facebook Custom Audience by logging into your Facebook account and changing your privacy or advertising settings as per Facebook’s opt-out instructions. You may also use your Facebook account settings to unlink your Facebook account from the Sites. Twitter, Pinterest, Instagram, and other social media services may also have their own opt out services.

Please note that we do not control how other parties manage their opt-out processes.

We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from external parties. We or external parties may collect personal information about your online activities over time and across different online services when you use the Sites.

You can set your browser to refuse cookies from websites, but if you do so, you may not be able to access or use portions of the Sites, or certain offerings on the Sites may not function as intended or as well.

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3. USE OF INFORMATION

WKKC may use information collected through the Sites, including personal information and for various purposes, which may be more explained in notices at or before collection of any specific information, including but not limited to:

• allow you to use the Sites and to provide you related service, including providing support and respond to questions from customers, address information security and/or privacy issues, debug and detect security incidents or abnormalities, fulfill, respond to, and document privacy rights requests, network functioning, and troubleshooting, contact you with administrative communications and, in our discretion, changes to Sites’ policies;
• fulfill transactions and process your registration, orders and payments, including verifying the information you provide is accurate and active or to remember and restore your preferences when you return to the Sites;
• administer and develop our business relationship with you and the company you represent;
• assess your employment application for a position with WKKC and prepare related governmental and internal statistics reports;
• personalize your online experiences and tailor content, recommendations and offers we display to you on the Sites and elsewhere online;
• provide you with information, products or services that you have requested or agreed to receive or that we otherwise believe will interest you, including, information and special offers from us, our advertisers, and our third party business partners;
• conduct internal analyses, such as surveys, studies, and market research and improve the Sites, our products and services and for internal business purposes and monitor and analyze trends, usage, and activities of visitors and users of the Sites;
• to comply with applicable laws, regulations, or legal process as well as industry standards and our company policies,
• investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process;
• prevent, investigate, identify, or take any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates our policies;
• 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;
• such other purpose you may consent.

We may collect, use, and disclose your personal information as required or permitted by applicable law. We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements.

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4. DISCLOSURE OF INFORMATION

Certain personal information that you upload to the Sites may be publicly available to other users on the Sites (such as promotion winners’ lists).

We may share information we collect about you within the WKKC, our subsidiaries, members, parent, and affiliates worldwide.

From time to time we may enter into an arrangement with another company that is not owned by or affiliated with us to provide additional features on the Sites. These arrangements may include business partners, sponsors, and co-branded online services (referred to here as “co-branded services”). Any information, including personal information, that you provide on one of these co-branded services may be shared with these partners. By participating in activities or providing your information on these co-branded services, you consent to our providing your information to those partners. Separate privacy policies may apply to these partners’ uses of your personal information.

We may use vendors to help us operate our business and the Sites, or administer activities on our behalf, such as sending emails, promotion or loyalty program administration, Sites maintenance, customer service, payment processing, web analytics, maintenance, online advertising, certain social media plug-in integrations, and security execution and clearing services. When we disclose personal information to vendors, we strive to enter into a contract requiring the recipient to keep that personal information confidential and only use it as necessary to perform business purposes or as otherwise permitted by applicable law. Our service providers may engage subcontractors to enable the service providers to perform services for us.

We may share your personal information in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, bankruptcy, or any other business transaction), including negotiations of such transactions.

Information, including personal information, may also be shared by us or our vendors: (i) as required or permitted by applicable law, which may include lawful access by local or foreign courts, law enforcement, or other government authorities; (ii) 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; (iii) necessary to support any audit, or to comply with similar corporate governance functions; (iii) to enforce our policies, or to protect our or others’ legal rights, property, or safety, or (iv) when you otherwise consent or direct us to share information, such as where you use the Sites to send direct messages to others or interact with external parties directly.

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5. PROMOTIONS

We may operate sweepstakes, contests, raffles, and similar promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require registration or submitting personal information. If you choose to participate in a Promotion, your personal information may be disclosed to third parties as described in the terms applicable to that Promotion. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. Insofar as the terms applicable to a particular Promotion conflict with this Privacy Notice, the terms applicable to the Promotion shall control.

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6. OTHER ONLINE SERVICES

The Sites may contain links to, or features of, other online services that are not operated by WKKC. This Privacy Notice does not apply to those online services, which may have their own privacy policies or notices that you should review to understand how they may use or disclose your personal information. WKKC is not responsible for the content or privacy practices of any linked websites that we do not control.

We may also receive information about you from external parties. For example, if you are on another website that provides information and you request to receive information from WKKC that website will forward your contact and other information to us so that we may contact you as requested. External parties may also provide information about you in connection with a marketing arrangement we may have with those external parties.

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7. CHILDREN'S PRIVACY

The Sites are generally 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.

There are some Sites that may be intended for certain audiences that may include certain age ranges, in which case we may provide additional or separate privacy notices to address those specific audiences. Such privacy notices may clarify further the data collected through the applicable Site and should such audience-specific privacy notices contradict this Privacy Notice, the audience-specific Privacy Notice shall govern for the stated specific audience.

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8. SECURITY

We strive to maintain appropriate administrative, technical, and physical safeguards that are designed to help protect personal information collected or received through the Sites. Although we follow reasonable procedures to safeguard information, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect. You use our Sites and provide us with your information at your own risk.

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your-choices

A. Your Choices Generally.  Subject to applicable laws in your jurisdiction, and subject to the retention periods and data storage of your personal information, we provide choices related to your personal information. You may contact us regarding your choices as per the appropriate WKKC entity for your jurisdiction as described at the top of this Privacy Notice, or you may make a request regarding your privacy rights through our privacy portal .

We may, subject to law, need to verify your identity and the validity of the request before fulfilling your request. This includes verifying to a high degree of certainty for certain choices you may make and depending on the sensitivity of the personal information.

Authorized agents who meet the agency or power of attorney requirements under law may submit requests on behalf of an individual. We may require authorized agents to provide information as required by law such as a verifiable written authorization from the individual that the agent has the individual’s permission to submit the request.

Note that if some of the personal information we maintain is not sufficiently associated with personal information we have verified to be related to the identity of the requestor, we will not include such information in response to the request. Applicable law may require or permit us to decline your request. For example, without limitation, where we do not maintain the personal information in a searchable or reasonably accessible format and where we maintain the personal information solely for legal or compliance purposes. If we decline your request, we will tell you why, subject to legal restrictions.

You are not required to create a password-protected account with us to make a request, but if you have a password-protected account with us, you may be able to use your account to do so, if the Sites allows you to.

Please note we are not obligated to comply with requests to the extent that doing so would infringe on our, or any other person’s or party’s, rights, or conflict with applicable law.

As permissible by law, we do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded, in which case we may limit the response and/or condition it on payment of our costs.  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.

Our responses to privacy requests may be subject to legal requirements, such as responding to you within a certain timeframe, in which case we will provide you information about the process of your request.

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B. Access and Portability.  Subject to applicable law, you may have the option to access your personal information, including:

• The categories of personal information we have collected, used, disclosed, and sold about you.
• The categories of sources from which we collected your personal information.
• The purposes for collecting or selling your personal information.
• A list of the categories of personal information disclosed, along with the categories of recipient for each category of personal information, or that no disclosure occurred.
• A list of parties we have disclosed your information to for the other parties’ own direct marketing purposes.
• The specific pieces of personal information we have collected, used, and disclosed about you.

You may be able to access this information through a registered account, if applicable. Additionally, subject to applicable law, you may be able to request a machine-readable copy of your personal information to you or an external party of your choice.

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C. Revisions to your Personal Information.  Subject to applicable law, you may have the option to revise your personal information to ensure its accuracy, such as when you are logged into a registered account through your account or profile settings or preferences.

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D. Deletion. Subject to applicable law, you may request that we delete or remove from public view your personal information. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. For example, we may retain some or all of your personal information that you request to be deleted, without limitation, to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate purposes, including maintaining business records, to comply with applicable laws and regulations, to exercise or defend legal claims, and to cooperate with law enforcement.

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E. Email Marketing. If you prefer to no longer receive any marketing emails from us, you may opt out of an email subscription by using the unsubscribe link located in our emails or by contacting us (forwarding the newsletter, if applicable, and including in the Subject line the word “Unsubscribe”). However, please note that regardless of your opt-in preferences, we reserve the right to send you certain communications relating to your use of our Sites, service announcements, notices of changes to this Privacy Notice, or similar administrative or transactional messages, and these transactional account messages.

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F. Non-Discrimination Rights.   As prohibited by law, we will not discriminate against you in a manner prohibited by law for exercising any of your privacy rights under applicable law.

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G. United States Privacy Rights.  If you are a resident of California or another U.S. state, please visit our  US Privacy Notice and Do Not Share or Sell My Information sites for additional disclosures and information about your rights.

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H. Mexico Privacy Rights:  If you are a resident of Mexico, subject to applicable law, you may, in addition to the general choices described above, you may also oppose the use of your personal information for specific purposes.

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10. INFORMATION FOR USER OUTSIDE THE UNITED STATES

All Users:  If you are visiting the Sites from outside the United States, please be aware that information we obtain about you will be processed in the United States or in other jurisdictions. By using the Sites, you agree that any personal information which you provide will be treated in accordance with the laws of the United States. In addition, you acknowledge and consent to the international transfer and processing of your personal information as described in this Privacy Notice. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence.

To the extent personal information is transferred out of the country where the owner of that personal information lives, such as to WKKC 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. WKKC 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 or providing data to WKKC so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by WKKC and standardized corporate safeguards and contractual for internal data transfers to WKKC affiliates in third countries which are deemed to provide an inadequate level of data protection.

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11. CONTACTING US

If you have any questions or comments about this Privacy Notice, please contact us at privacy.consumeraffairs@wkkellogg.com.

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

Website: Contact Us

Postal Address: WK Kellogg Co

Attention: Consumer Affairs – Privacy Office

1 Kellogg Square

Battle Creek, MI 49016

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