WK KELLOGG CO PRIVACY NOTICE

1. COLLECTION OF PERSONAL INFORMATION

“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.

The Personal Information we obtain about you may vary depending on the nature of your interactions with us and may not include all the categories listed below. We obtain the following categories of Personal Information directly from you; automatically when you use our digital properties, such as websites; from service providers and other vendors, such as customer service providers, marketing agencies and firms, marketing research agencies, internet service providers, and data analytics providers; from social networks, data brokers, and data resellers; from government entities, vendors or external parties providing features; from research or focus group providers; and drawn from the other categories of Personal Information we collect.

• Contact Information and Other Identifiers.  You may provide us your name, address, email, telephone number, fax number, unique personal identifier, online identifier, IP address, 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, account 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.
• Professional or Employment-related Information. We may collect your organization name and job title.
• Commercial Information. We may collect records of products or services purchased, obtained, or considered through the Services as well as purchasing or consuming histories or tendencies, including coupon history.
• Audio, Electronic, Visual, or Similar Information. We may collect this type of information when you interact with us, such as recordings of customer service calls or when you submit audio/video submissions for social media promotions.
• Internet or Other Electronic Network Activity Information.  We may obtain Internet or other similar activity, browsing history, search history, information on your interaction with our Services, application logs, or device data and registration. This may include your usage of the Services or information that is necessary for the proper functioning or improvement of the Services, such as: times and dates and the extent of your usage; time zone, language, screen resolution, and other usage preferences you select when using the Services; search terms related to Services; the URL or advertisement that may have referred you to the Services; and 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.
• Geolocation Data.  You may provide your location to obtain location-specific content, such as store locations or we may infer your location based on your IP address.
• External Service Information.  We may obtain information about you from external services, such as where you choose to use a 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, as well as 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.
• Characteristics of Protected Classifications. You may provide us information about characteristics requiring certain protections under applicable state or federal law. For example, we may collect age and date of birth, marital status, race, ancestry, ethnicity or national origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, or disability.
• 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.

Some of the Personal Information we process is considered sensitive under certain privacy laws, including race, ancestry, ethnicity or national origin, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, or disability.

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 Services. In those cases, we will apply this Privacy Notice to the combined information.

2.  COOKIES AND OTHER TRACKING TECHNOLOGIES

In addition to any Personal Information or other information that you choose to submit through the Services, we and our vendors may use cookies, web beacons, pixels, tags, and other similar technologies (collectively, “Cookies”) to collect information when you interact with the Services.  These Cookies may collect information about your usage and activities (such as your IP address and device identifier, the browser you are using, length and time of visit and pages visited); geolocation data (to deliver content based on your location); and other details about how you interact with our Services (including clicks, cursor movement, scrolls, and keystroke activity). This information is used by WKKC and our vendors for a variety of purposes, including to help us route traffic between servers, retain user preferences, and allow account log ins; understand how the Services are functioning; understand, improve, and research features and content on the Services, including how users use the Services and the content and products that users view most frequently; provide features related to social media services, such as to enable you to share our content with your friends and networks; verify your location and deliver or restrict content based on your location; prevent fraud and protect and secure our Services; personalize and improve your experiences; provide advertisements; improve and measure our advertising campaigns; and provide you with more relevant content, advertisements, and offers on third-party websites and services.

The Services may enable you to change your preferences in relation to Cookies, including opting out of some or all of them, subject to applicable law and what Cookies may be necessary to enable the Services’ functionality. You can set your browser to disable or refuse Cookies from websites, but if you do so, you may not be able to access or use portions of the Services, or certain offerings on the Services may not function as intended or as well. Browsers offer different functionalities and options, so you may need to set them separately. Your opt-out choice may apply only to the browser or device you are using when you opt out, so you should update your settings on each of your browsers and devices. Your browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. WKKC does not process "Do Not Track" directives your browser may send.

We have 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.

The following services or organizations offer tools that you can use to limit or opt out of Cookies:

• Google: You can learn more about how Google collects and processes data in the Google Privacy Policy. Information about Google Analytics’ current opt-outs for web is available here. You can opt out of Google Analytics Advertising features directly with Google through its Ads Settings, and Ad Settings for mobile apps functionality.
• Industry Groups: Certain external parties may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program the Network Advertising Initiative (“NAI”). You can learn more about the DAA AdChoices Program at http://www.youradchoices.com and the NAI Tool at https://thenai.org/how-to-opt-out.

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. 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 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 Services.

3. USE OF PERSONAL INFORMATION

WKKC may use information collected through the Services, including Personal Information, for various purposes, including but not limited to:

• Business Operations, such as to 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 Services; administer and develop our business relationship with you and the company you represent, our partners, service providers, and vendors; and fulfill purposes that we describe to you at the time we collect your Personal Information.
• Services Operations and Improvement, such as to personalize your online experiences and tailor content, recommendations and offers we display to you on the Services and elsewhere online; maintain, operate, optimize, and provide access to our Services conduct internal analyses, such as surveys, studies, and market research; and improve the Services and our products; monitor and analyze trends, usage, and activities of visitors and users of the Services; repair or improve the quality of our Services; track and respond to quality and security issues; debug our Services to identify and repair errors that impair existing or intended functionality; develop new or enhanced products and offerings; and ensure our Services operate effectively.
• Communications, such as to 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; respond to your feedback or questions; understand how you interact with our communications; and improve the relevance and usefulness of communications.
• Advertising and Marketing, such as to send you promotional materials, serve advertisements, measure the effectiveness of our advertisements and marketing, and develop insights to improve our Services and provide our users with enhanced features and functionalities.
• Security, Legal, and Compliance, such as to safeguard our Services; address information security and/or privacy issues; debug and detect security incidents or abnormalities; 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 or procedures; manage risks, investigations, reporting, and other compliance activities; detect potentially fraudulent transactions; respond to court orders or other government and law enforcement mandates or requests; identify or manage legal actions related to our or others’ rights or property; and support actual or threatened claims, defenses, or declarations in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel.
• Corporate Restructuring, such as to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as part of regular business operations or pursuant to a bankruptcy, liquidation, or similar proceeding.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose Personal Information for the purposes described above to the following parties:

• Our Related Entities, including our subsidiaries, members, parent, and affiliates worldwide.
• Business Partners, Sponsors, and Co-branded Online Services, including another company that is not owned by or affiliated with us to provide additional features on the Services. 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.
• Service Providers and Other Vendors that help us operate our business and the Services, including to administer activities on our behalf, such as email communications, promotion or loyalty program administration, Service maintenance, customer service, payment processing, web analytics, maintenance, online advertising, certain social media plug-in integrations, and security services.
• Prospective or Actual Purchasers, Investors, or Successor Entities, and Other Parties to corporate Transactions in connection with a contemplated or an actual reorganization of our business, or in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets. This may include processing for the purpose of permitting the due diligence required to determine whether to proceed with a transaction.
• Regulators, Professional Advisers, Law Enforcement Agencies, and Other Similar Entities for legal and compliance purposes, including complying with any legal process; safeguarding our operations; allowing us to pursue available remedies or limit the damages that we may sustain; as required or permitted by applicable law, which may include lawful access by local or foreign courts, law enforcement, or other government authorities; 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; as necessary to support any audit, or to comply with similar corporate governance functions; to enforce our terms and policies; and to protect our or others’ legal rights, privacy, property, or safety.
• With Your Consent or At Your Direction when you consent or direct us to share information, such as where you use the Services to send direct messages to others or interact with external parties directly.

Certain Personal Information that you upload to the Services may be publicly available to other users on the Services, such as promotion winners’ lists.

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.

6. INTERACTIVE FEATURES

We may engage vendors to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on our Services to answer questions and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf and that the features may utilize artificial intelligence.

7. OTHER ONLINE SERVICES

The Services 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.

8. CHILDREN'S PRIVACY

The Services 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 Services. If we learn that we have received Personal Information directly from a child who is under the age of 13, we will delete the Personal Information in accordance with applicable law.

There are some Services 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 Services and should such audience-specific privacy notices contradict this Privacy Notice, the audience-specific Privacy Notice shall govern for the stated specific audience.

9. SECURITY

We strive to maintain appropriate administrative, technical, and physical safeguards that are designed to help protect Personal Information collected or received through the Services. 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 Services and provide us with your information at your own risk.

10. PERSONAL INFORMATION RETENTION

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

• The 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;
• The 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 in the Contact Us section.

11. YOUR CHOICES

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 Services, service announcements, notices of changes to this Privacy Notice, or similar administrative or transactional messages.

Cookie Preferences. You may opt out of certain Cookies using the “Cookie Preferences” link in the Site footer.

United States Privacy Rights. If you are a resident of California or another U.S. state, please review the U.S. Privacy Disclosures section below for additional disclosures and information about your rights.

Canada Privacy Rights. If you are a resident of Canada, please review the Canada Privacy Disclosures section below for additional disclosures and information about your rights.

12. INFORMATION FOR USERS OUTSIDE THE UNITED STATES

If you are accessing the Services 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 Services, 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.

13. U.S. PRIVACY DISCLOSURES

This section is provided for residents of states with comprehensive privacy laws applicable to WKKC including the California Consumer Privacy Act (“CCPA”), (collectively, the “Applicable States”). In the event of a discrepancy between this U.S. Notice and our Privacy Notice this notice shall prevail for residents of Applicable States.

References to Personal Information include “Personal Data” and similar terms defined in Applicable State privacy laws.

If you are a job applicant residing in California, please see our Applicant Privacy Notice for additional disclosures.

A.  SELLING AND SHARING FOR TARGETED ADVERTISING

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 cross-contextual behavioral advertising and targeted advertising (collectively, “Targeted Advertising”), including through Cookies. We may share your Personal Information for 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. Certain Applicable State privacy laws may consider Targeted Advertising to be a sale of Personal Information. In this context, we sell and/or share for Targeted Advertising the following categories of Personal Information: Identifiers, Personal Records as 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, and 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 through Cookies. 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.

B.  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, Access, and Data Portability. You have the right to confirm whether we are processing your Personal Information, access your Personal Information, and request to receive the Personal Information we hold about you in a portable format.
• Right to Request Third Party Information. Connecticut, Minnesota, and Oregon consumers may request a list of specific third parties which we may have disclosed Personal Information. Delaware and Maryland consumers may also request a list of categories of third parties to which we may have disclosed Personal Information.
• 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 Cookies, please click our Cookie Preferences link on the bottom of the Site. 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 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.

WKKC does not engage in profiling or other automated decision-making in furtherance of decisions that produce legal or similarly significant effects.

If you choose to exercise any of your privacy rights, we will not discriminate against you.

C.  HOW TO EXERCISE YOUR PRIVACY RIGHTS

To exercise your privacy rights, please follow the instructions above, 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 above.

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.

D.  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 above.

The information in this Privacy Notice that describes our Personal Information processing practices also describes our practices for the 12-month period prior to the Last Updated date.

i. Personal Information Collection, Use, and Disclosure

We also process the following category of Personal Information about California residents: Personal Records as described in Cal. Civ. Code § 1798.80(e), 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.

We use and disclose this category of Personal Information as described in the Use of Personal Information and Disclosure of Personal Information sections above.

ii. 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; and 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 our Cookie Preferences link on the bottom of the Site.

iii. 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 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.

14. CANADA PRIVACY DISCLOSURES

If you are a resident of Canada, please review the WK Kellogg Co’s Canadian Privacy Notice by clicking on your language of preference below:

• French
• English

15. CARIBBEAN PRIVACY DISCLOSURES

This section applies to individuals residing in certain Caribbean jurisdictions, including Barbados, Jamaica, The Bahamas, the Cayman Islands, and other jurisdictions whose privacy laws apply to WKKC's processing of Personal Information. In the event of a conflict between this section and another part of this Privacy Notice, this section will control to the extent required by applicable law.

A.  Legal Bases for Processing

Depending on the circumstances and applicable law, we may process your Personal Information where:

• you have provided your consent;
• processing is necessary to provide you with products, services, promotions, loyalty program benefits, or account functionality that you have requested;
• processing is necessary to comply with legal or regulatory obligations;
• processing is necessary to protect the vital interests of an individual;
• processing is necessary for the establishment, exercise, or defense of legal claims; or
• processing is necessary for our legitimate business interests, provided such interests are not overridden by your rights and freedoms.

Where we rely on your consent to process Personal Information, you may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent will not affect the lawfulness of processing conducted before the withdrawal.

B.  International Transfers of Personal Information

WKKC operates internationally and may transfer, store, access, or process Personal Information in the United States, Canada, and other countries in which WKKC, its affiliates, service providers, business partners, or vendors operate. As a result, your Personal Information may be accessible to foreign governments, courts, law enforcement agencies, or regulatory authorities under the laws of those jurisdictions.

Where required by applicable law, WKKC implements appropriate safeguards designed to protect Personal Information transferred across borders, including contractual protections, vendor obligations, internal privacy standards, and other measures intended to provide a level of protection substantially similar to that required under applicable law.

C.  Sensitive Personal Information

In certain circumstances, we may collect or process Personal Information that is considered sensitive under applicable law, such as information concerning racial or ethnic origin, health information, disability status, religious beliefs, sexual orientation, gender identity, or other categories protected by applicable law.

We only process Sensitive Personal Information where permitted by law and, where required, with your explicit consent or another lawful basis recognized under applicable law. We implement additional safeguards appropriate to the nature and sensitivity of such information.

D.  Your Privacy Rights

Subject to applicable law and certain exceptions, you may have some or all of the following rights regarding your Personal Information:

• the right to obtain confirmation regarding whether we process your Personal Information;
• the right to access Personal Information that we maintain about you;
• the right to request correction or updating of inaccurate Personal Information;
• the right to request deletion or erasure of Personal Information in certain circumstances;
• the right to object to or restrict certain processing activities;
• the right to withdraw consent where processing is based on consent;
• the right to request a portable copy of certain Personal Information;
• the right to object to the use of Personal Information for direct marketing purposes;
• the right to request information regarding cross-border transfers of your Personal Information; and
• the right not to be subject to certain automated decision-making activities where provided under applicable law.

WKKC does not use automated decision-making to make decisions that produce legal or similarly significant effects on consumers. To exercise any available privacy rights, please use the contact information provided in the "Contact Us" section or submit a request through our Privacy Portal.

E.  Direct Marketing Communications

Where required by applicable law, we will obtain consent before sending certain marketing communications. You may opt out of receiving marketing communications at any time by using the unsubscribe mechanism included in our communications or by contacting us using the methods described in this Privacy Notice.

Please note that even if you opt out of marketing communications, we may continue to send non-promotional communications regarding your account, transactions, requests, contests, promotions, service updates, changes to this Privacy Notice, or other administrative matters.

F.   Retention of Personal Information

We retain Personal Information only for as long as reasonably necessary to fulfill the purposes for which it was collected, as described in this Privacy Notice, including satisfying legal, regulatory, accounting, reporting, and legitimate business requirements. The retention period applied to Personal Information depends on the nature of the information, the purpose for which it was collected, and applicable legal requirements.

G.  Complaints and Regulatory Authorities

If you believe that WKKC's processing of your Personal Information violates applicable law, we encourage you to contact us first so that we can attempt to resolve your concern.

Subject to applicable law, you may also have the right to lodge a complaint with the privacy or data protection authority responsible for your jurisdiction, including the data protection or information commissioner, ombudsman, or similar supervisory authority with responsibility for enforcing applicable privacy laws.

16. CONTACT US

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