WK Kellogg Co U.S. Consumer Privacy Notice
Last Updated: July 1, 2024
This U.S. Consumer Privacy Notice (“U.S. Notice”) supplements our WK Kellogg Co Privacy Notice (“WKKC”, “Privacy Notice") and describes how we collect, use and otherwise process Personal Information for residents of states with comprehensive privacy laws applicable to WKKC including the California Consumer Privacy Act (“CCPA”), (collectively, the “Applicable States”). If you are not a resident of an Applicable State, please refer to the Your Choices section in the Privacy Notice for information about how you can exercise your choices regarding your Personal Information. In the event of a discrepancy between this U.S. Notice and our Privacy Notice this notice shall prevail for residents of Applicable States.
In certain circumstances we may provide additional or specific privacy notices to specific audiences. Such privacy notices shall provide notice of additional processing activities. Should such audience-specific privacy notices contradict this Notice, the audience-specific Privacy Notice shall govern for the stated specific audience.
If you are a job applicant, please see our Applicant Privacy Notice. If you are an applicant residing in California, please see our California Applicant Privacy Noticefor additional disclosures. If you are a WKKC employee, please see our HR Data Privacy Policy for additional disclosures. If you are an employee residing in California, please see our California Employee Privacy Notice for additional disclosures.
Unless otherwise noted, the information below that describes how and why we collect, use, and disclose your Personal Information also describes how we have collected, used, and disclosed Personal Information in the preceding twelve (12) months.
1. PERSONAL INFORMATION WE COLLECT, USE, AND DISCLOSE
“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, and includes “Personal Data” as defined in Applicable State privacy laws. Personal Information does not include information that is publicly available, de-identified, or aggregated.
We collect, use, and/or disclose the following categories of Personal Information about residents of Applicable States. This Personal Information may be obtained directly from you; automatically when you use our digital properties, such as websites; from service providers, such as marketing agencies and firms, marketing research agencies, internet service providers, and data analytics providers; from government entities; from social networks; from data brokers; from research or focus group providers; and drawn from the other categories of Personal Information we collect.
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 items listed below.
Identifiers
Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers
Purpose for Collection, Use, and Disclosure:
- Allow you to use our digital properties and to provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Personal Records
Personal records, including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, or medical information (this category includes Personal Information described in Cal. Civ. Code § 1798.80(e))
Purposes for Collection, Use, and Disclosure
- Allow you to use our digital properties and to provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Characteristics of Protected Classifications
Characteristics of protected classifications under applicable state 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, or disability
Purposes for Collection, Use, and Disclosure
- Allow you to use our digital properties and to provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Commercial Information
Commercial information, including, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Purposes for Collection, Use, and Disclosure
- Allow you to use our digital properties and to provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Internet or Other Electronic Network Activity Information
Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, or social media account information or advertisement
Purposes for Collection, Use, and Disclosure
- Allow you to use our digital properties and to provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Geolocation Data
Geolocation Data
Purposes for Collection, Use, and Disclosure
- Allow you to use our digital properties and to provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Audio, electronic, visual, thermal, olfactory, or similar information
Audio, electronic, visual, thermal, olfactory, or similar information
Purposes for Collection, Use, and Disclosure
- Allow you to use our digital properties and to provide you related services
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Professional or employment-related information
Professional or employment-related information
- If you are a WKKC employee, please see our HR Data Privacy Policy for additional disclosures.
- If you are an employee residing in California, please see our California Human Resources Privacy Notice for additional disclosures.
- Job applicants can find additional disclosures here.
Purposes for Collection, Use, and Disclosure
- To provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Inferences
Inferences used to create a profile reflecting the consumer’s preferences,characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Purposes for Collection, Use, and Disclosure
- To provide you related services
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
Sensitive Personal Information
Sensitive Personal Information, including:
Personal Information that reveals a consumer’s racial or ethnic origin, Personal Information collected and analyzed concerning a consumer’s health, or Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation
Purposes for Collection, Use, and Disclosure
- To provide you related services
- Fulfill transactions and process your registrations, orders and payments
- Administer and develop our business relationship with you and/or the company you represent
- Personalize your online experiences and tailor content, recommendations, and offers we display to you
- Provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you
- Conduct internal analyses, such as surveys, studies, and market research
- For internal business purposes and to improve our digital properties, products, and services
- Monitor and analyze trends, usage, and activities of our digital property visitors and users
- Comply with applicable laws, regulations, and legal process, as well as industry standards and WKKC policies
- Investigate, prevent, identify, or take action related to suspected or actual fraudulent or illegal activity; claims or legal actions; or any activity that violates our policies or procedures
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
- For purposes you consent to at the time of collection
Categories of Recipients
- Affiliated and related companies
- Service providers
- Business partners, sponsors, and co-branded online services
- Professional advisors
- Public authorities or government bodies
- External auditors
2. HOW WE SHARE AND SELL PERSONAL INFORMATION
Under Applicable State privacy laws, a “sale” of Personal Information does not necessarily involve an exchange of money. We do not knowingly sell Personal Information for monetary consideration, but we may disclose Personal Information to vendors for valuable consideration to facilitate interest-based advertising, cross-contextual behavioral advertising, targeted advertising, and other advertising and marketing, including through cookies or other tracking technologies through our Sites (“Online Tracking Technologies”). We may share your Personal Information for cross-context behavioral or targeted advertising purposes to show you advertisements based on Information gathered from your activities over time and across nonaffiliated websites and applications to predict and anticipate your interests and preferences (“Targeted Advertising”). Certain Applicable State privacy laws may consider Targeted Advertising a sale. You can manage Online Tracking Technologies through the Cookie Preferences link on the bottom of our webpages. In this context we sell and/or share for Targeted Advertising the following categories of Personal Information:
- Identifiers
- Personal records (including Personal Information described in Cal. Civ. Code § 1798.80(e))
- Characteristics of protected classifications
- Commercial information
- Internet or other electronic network activity information
- Geolocation data
- Professional or employment-related information
- Inferences
- Sensitive Personal Information
The categories of recipients to whom we may have sold and shared Personal Information include our vendors and other third parties for Targeted Advertising, as well as other marketing and advertising services that we utilize on our digital properties. We only “sell” Personal Information to third parties as defined in Applicable State privacy laws for the purposes of cookies or other tracking technologies. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.
NOTICE: We may sell your sensitive personal data.
3. YOUR PRIVACY RIGHTS
Residents of certain states have privacy rights under Applicable State privacy laws. To exercise your rights, please refer to the How to Exercise Your Privacy Rights section below.
Right to Confirm and Access. You have the right to confirm whether we are processing your Personal Information and access your Personal Information. Oregon Consumers may also request a list of third parties to which we may have disclosed your Personal Information.
Right to Data Portability. You may request to receive the Personal Information we hold about you in a portable format.
Right to Delete Your Personal Information. You have the right to request that we delete your Personal Information, 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.
Right to Opt Out of Targeted Advertising and Sales. You have the right to opt out of the sale of your Personal Information and the processing of your Personal Information for the purposes of Targeted Advertising. To opt out of Targeted Advertising and sales using Online Tracking Technologies, please click our Cookie Preferences link on the bottom of the webpage. If you choose to use the Global Privacy Control browser signal, you will only be opted out of online Targeted Advertising, and will need to turn it on for each browser you use.
Right to Opt-Out of Profiling. You have the right to opt out of the processing of your Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not profile for these purposes so do not offer this right.
Right to Appeal. If you have been denied one of these enumerated rights, you may have the right to appeal for reconsideration if you are a resident of certain Applicable States.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under Applicable State privacy laws, you also have the right not to receive discriminatory treatment by us.
4. ADDITIONAL CALIFORNIA DISCLOSURES
Residents of California have additional privacy rights under the CCPA. To exercise your rights, please refer to the How to Exercise Your Privacy Rights section below.
A. Additional California Rights
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
-
The categories of Personal Information we have collected about you, including:
- The categories of sources from which the Personal Information was collected.
- Our business or commercial purposes for collecting, selling, sharing, or disclosing Personal Information.
- The categories of recipients to which we disclose Personal Information.
- The categories of Personal Information that we sold or shared, and for each category identified, the categories of third parties to which we sold or shared that particular category of Personal Information.
- 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.
-
The specific pieces of Personal Information we have collected about you.
Right to Limit Use and Disclosure of Sensitive Personal Information.You have the right to direct us to limit the use and disclosure of your Sensitive Personal Information to uses/disclosures that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us; and to improve, upgrade, or enhance such services or devices. WKKC only uses and discloses your Sensitive Personal Information to provide you with personalized advertisements based on your interests and activities and for the limited purposes described in this California section. To limit our use of your Sensitive Personal Information, please click here to access our Privacy Portal and we will opt you out of personalized advertising.
Rights Related to Automated Decision-Making.You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. WKKC uses profiling to provide you with personalized advertisements based on your interests and activities. To opt out of automated decision-making, please click here to access our Privacy Portal and we will opt out of personalized advertising.
B. 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 California section or otherwise authorized by law. This generally means holding the Personal 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;
- Your Personal Information is reasonably required to protect or defend our rights or property; or
- We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.
Where Personal 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.
C. California Shine the Light
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 Personal Information is shared for those third parties’ or 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 information about our compliance with this law by contacting us using the information in the How to Contact Us section below.
Letters should be addressed to Attn: Legal Department – Privacy/Shine the Light. Any such request must include your name and “California Shine the Light Privacy Rights Request” in the first line of the description and, if sent by mail, must include your street address, city, state, and zip code.
Please note that “Shine the Light” rights and CCPA rights are granted by different laws and must be exercised separately.
5. HOW TO EXERCISE YOUR PRIVACY RIGHTS
To exercise your privacy rights, please submit a request through our Privacy Portal or call us at 1-800-962-1413.
Please note that, if you submit a privacy rights request, you may be asked to provide certain information 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 below.
Sometimes we are unable to process requests related to your Personal Information, in which case your request will be denied. Residents of certain Applicable States have the right to appeal such denial if you believe it was made in error. Please note that if you make a privacy rights request, we will retain the Personal Information submitted in connection with your request for recordkeeping purposes.
6. HOW TO CONTACT US
If you have any questions about how we handle your Personal Information, please contact us at:
Email: privacy.consumeraffairs@wkkellogg.com
Phone: 800-962-1413 (9a.m.-6p.m. ET)
Postal Address: WK Kellogg Co, Attention: Consumer Affairs – Privacy Office, 1 Kellogg Sq, North Tower, Battle Creek, MI 49016