In this privacy notice (\u201cNotice<\/strong>\u201d), Oreo (\u201cOreo<\/strong>\u201d, \u201cwe<\/strong>\u201d, \u201cour<\/strong>\u201d, \u201cus<\/strong>\u201d) describes our collection, use, and disclosure of the Personal Information that we collect about you, such as through our websites, mobile applications, forms or cloud-based services and communication platforms with a link to this Privacy Notice (collectively, \u201cSites<\/strong>\u201d) and the products and services available through our Sites, and interactions with you (our \u201cServices<\/strong>\u201d). This Notice does not apply to Mondel\u0113z Global Sites and Services that do not display or link to this Notice. Please note that we may provide you with additional disclosures or notices based on your interaction with us (e.g., if you apply for employment with us) or based on your residency. References to \u201cPersonal Information\u201d in this Privacy Notice means information that identifies or can reasonably identify users of the Site (\u201cyou<\/strong>\u201d) personally. This Notice applies only to U.S. consumers. <\/p>\n\n\n\n
2. Personal Information We Collect About You<\/h2>\n\n\n\n
In the preceding 12 months, we have collected the following categories of Personal Information directly from you, about you from other sources, and as you use our Services and Sites.<\/p>\n\n\n\n
Personal Information Category<\/strong><\/td>
Categories of Personal Information Collected<\/strong><\/td>
Categories of Sources from Which Personal Information was Collected<\/strong><\/td><\/tr>
A. Identifiers.<\/strong><\/td>
A real name; alias; postal address; unique personal identifier; online identifier; Internet Protocol address; email address; account name; and other similar identifiers.<\/td>
This data is collected directly from you through our Sites and Services, from other parties like marketing agencies, data brokers, social media platforms, or from data analytics providers when you interact with our Sites and Services. <\/td><\/tr>
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code \u00a7 1798.80(e)).<\/strong><\/td>
A name; address; telephone number; bank account number; credit card number, debit card number, or any other financial information.Some Personal Information included in this category may overlap with other categories.<\/em> We collect financial information for billing and transactional purposes in connection with providing you our products and Services.<\/em><\/td>
This data is collected directly from you through our Sites and Services, from other parties like marketing agencies, data brokers, social media platforms, or from data analytics providers when you interact with our Sites and Services. <\/td><\/tr>
C. Commercial information.<\/strong><\/td>
Records of products or services purchased, obtained, or considered, or other purchasing history or tendencies<\/td>
This data is collected directly from you through our Sites and Services, from other parties like marketing agencies, data brokers, social media platforms, or from data analytics providers when you interact with our Sites and Services. <\/td><\/tr>
D. Internet or other similar network activity.<\/strong><\/td>
Browsing history; search history; information on a Consumer\u2019s interaction with a website, application, or advertisement.<\/td>
This data is collected directly from you through our Sites and Services, or from data analytics providers when you interact with our Sites and Services.<\/td><\/tr>
E. Inferences drawn from other Personal Information.<\/strong><\/td>
Profile reflecting a person\u2019s preferences; characteristics; behavior; attitudes.<\/td>
This data is collected directly from you through our Sites and Services, from other parties like marketing agencies, data brokers, social media platforms, or from data analytics providers when you interact with our Sites and Services. <\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n
3. How We Use Your Personal Information<\/h2>\n\n\n\n
We collect, use, disclose, and otherwise process your Personal Information, for the following business and commercial purposes:<\/p>\n\n\n\n
Provide and Improve our Services, Customer Services and Support Purposes:<\/strong> – To provide you with and maintain our Sites and Services.- To respond to your questions or comments regarding our products, and to communicate with you about your inquires.- To provide our Services to you, including financial incentives where proper consent has been given.- To develop and improve new products, features, content, or services.- To operate our Sites, including through the use of analytics software, and to address problems and review the usage and operations of such or our business.- To negotiate, conclude, and perform contracts with vendors.<\/td><\/tr>
Marketing, Advertising, and Communications:<\/strong> – Where permitted by applicable law, to contact you with information, newsletters, and promotional materials, including special offers promotions (contests, and sweepstakes), financial incentives, and other information we think may interest you from and about us or on behalf of our partners and affiliates.- To provide you with customized content, targeted offers, and advertising on our Sites, on other sites, or via email or text message, as permitted by applicable law.- To invite you to participate in surveys and provide feedback to us.- To associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications, and websites).- To send you alerts or other communications via SMS messages or other media or networks. You may opt-out of such communications at any time by following the opt-out instructions contained in the email or SMS you receive. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you transactional emails about your account or any Services you have requested or received from us.- To communicate with individuals that are, or who represent, consumers, vendors, or web users related to transactions.<\/td><\/tr>
Analytics and Research:<\/strong> – For market and consumer research or analytic purposes, such as to understand usage and activity trends and other statistical purposes, or for clinical research purposes. – To create a profile about a consumer reflecting the consumer\u2019s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.- We also may use data in aggregated form to determine relevant advertising and to evaluate the success of our advertising campaigns. – We also may disclose data in the aggregate with other entities to assist us with these purposes or for their own use.<\/td><\/tr>
Protecting Company Rights, Security, and Interests:<\/strong> – To protect the security or integrity of our Sites and our business and the safety, rights, property, or our security, the Services, any other entity, or the general public.\u00a0– To detect, prevent, or otherwise address fraud, security, or technical issues.\u00a0– To obtain legal advice, including for legal proceedings and litigation and also in connection with the sale, purchase or merger of a business.- To prevent or stop activity that we consider to be, or poses a risk of being, an illegal, unethical, or legally actionable activity, such as for security, credit or fraud prevention purposes.- To use as evidence in litigation.\u00a0– To enforce this Notice,\u00a0Terms of Use<\/strong>, or any other terms agreed between you and us.\u00a0<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n
4. When We Disclose Your Personal Information<\/h2>\n\n\n\n
We disclose your Personal Information in the following ways:<\/p>\n\n\n\n
Other Users<\/strong><\/p>\n\n\n\n
On certain Sites, you may post content, such as product reviews or ratings. Any such content is viewable by other visitors to our Sites. For example, reviews that you disclose on our Sites, in blogs, on message boards, social media or on other public areas on our Sites, become viewable to the community. Please exercise caution when disclosing Personal Information in these publicly viewable areas.<\/p>\n\n\n\n
Affiliates & Service Providers<\/strong><\/p>\n\n\n\n
We may disclose Personal Information among our brands, affiliates, and subsidiaries. In the course of doing business, we also employ other companies and individuals to perform certain functions as our Service Providers on our behalf. For example, we hire agencies to help us administer consumer promotions, to analyze data, to fulfill orders you place, and to provide customer service.<\/p>\n\n\n\n
Marketing Partners<\/strong><\/p>\n\n\n\n
We may conduct joint promotions with other companies. We may disclose with our promotional partners (and their service providers) certain Personal Information to conduct the promotion. We will not disclose this information to our promotional partners for any other purpose unless you consent to such disclosure. If you don\u2019t want us to disclose your Personal Information to our marketing partners, you may opt-out by submitting a request\u00a0here<\/strong>. However, if you opt-out of such marketing, this won\u2019t affect information we have already disclosed about you, and we may still send you our own marketing and promotional communications about information and ads we think you may be interested in (unless you have unsubscribed from receiving marketing communications from us).<\/p>\n\n\n\n
Data obtained through any SMS program will not be shared with any third parties for their own marketing reasons or purposes.<\/p>\n\n\n\n
Legal Compliance and Protecting Rights and Interest<\/strong><\/p>\n\n\n\n
In addition, we may disclose information where we think it’s necessary to investigate or prevent an actual or suspected crime or injury to ourselves or others, if required by law, or in response to a request from law enforcement authorities or other government officials, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal. We may also disclose your information to protect the safety, rights, property, and security of Mondel\u0113z Global, the Services, third parties, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which in our sole discretion, we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Notice.<\/p>\n\n\n\n
Business Transfers <\/strong><\/p>\n\n\n\n
During the normal course of our business, we may sell or purchase assets or equity. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity, including during negotiations related to such transactions. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to other parties. <\/p>\n\n\n\n
Aggregate and De-Identified Information<\/strong><\/p>\n\n\n\n
We may disclose aggregate, pseudonymized, anonymized, or de-identified information about you for marketing, advertising, research, compliance, or other purposes.<\/p>\n\n\n\n
International Transfers<\/strong><\/p>\n\n\n\n
For purposes disclosed in Section 3 (How We Use Your Personal Information), your Personal Information may be processed and accessed from countries other than your country, and where different data privacy laws apply. When Personal Information is transferred internationally, we use best efforts to ensure that the laws in force in the recipient’s country provide adequate protection. This includes, by way of example, the adoption of appropriate contractual measures to guarantee the adequate protection of Personal Information. <\/p>\n\n\n\n
5. Cookies and Other Tracking Technologies<\/h2>\n\n\n\n
Online Advertising<\/strong><\/p>\n\n\n\n
As described above, the advertisers and ad networks we work with may use technology such as cookies and web beacons\/pixel tags, or flash cookies when they advertise on our or external websites to provide you relevant advertisements based on your online behavior, search activities on our site and on other Sites, and demographic information relevant to your general location, so that the advertising you see on our Sites closely reflects your interests and needs. For more information on how to manage your cookie preferences see the How You Can Control Cookies<\/strong> <\/u><\/strong>section below.<\/p>\n\n\n\n
Custom Audiences and Matching<\/strong><\/p>\n\n\n\n
We may disclose certain information (such as your email address) to other parties \u2013 such as Facebook (more info on Facebook Custom Audience\u00a0here<\/strong>) so that we can better target ads and content to our users, and others with similar interests on these external platforms or networks (\u201cCustom Audiences\u201d). We may also work with ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. If you would like to opt-out of being included in our Custom Audiences going forward, email us\u00a0here<\/strong>\u00a0and we will opt you out of our future Custom Audiences.<\/p>\n\n\n\n
Interest-based Ads<\/strong><\/p>\n\n\n\n
We work with others to display more relevant advertising on our Services, and to manage our advertising on other sites, mobile apps and online Services. In order to display more relevant ads on our behalf and others, these ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information on our Services, on other sites and across different devices, which may be linked with certain offline data they may also collect IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device\u2019s geolocation information. These ad companies may use this information to provide you more relevant ads and content and to evaluate the success of such ads and content. As a result, our ads may be displayed to you on a search results page or on other sites.<\/p>\n\n\n\n
Analytics<\/strong><\/p>\n\n\n\n
We may use analytics companies, for example\u00a0Google Analytics<\/strong>\u00a0(see\u00a0privacy policy<\/strong>\u00a0and\u00a0opt-out<\/strong>), to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.<\/p>\n\n\n\n
Links and Social Plug-Ins<\/strong><\/p>\n\n\n\n
Our Sites may link to external websites and this Notice does not apply to those external sites. For information about the privacy practices that apply to such external sites, please check the privacy policy of the specific site you’re visiting to understand the privacy practices associated with that site. We are not responsible for the content or privacy practices of these websites.<\/p>\n\n\n\n
6. How You Can Control Cookies and Other Tracking Technologies<\/h2>\n\n\n\n
Privacy Preference Center<\/strong><\/p>\n\n\n\n
You can manage your consent for all but Strictly Necessary cookies in our Privacy Preference Center via the Cookies link (available in the footer of each Site). If you don\u2019t consent to some types of cookies, it might impact your use of the Sites and the services we can offer. <\/p>\n\n\n\n
To see which cookies are on our Sites and how these third parties use your Personal Information, click the Cookies link (available in the footer of each Site), and enter the Privacy Preference Center to choose the type of cookies from the menu on the left, then click on \u201cCookies Details.\u201d <\/p>\n\n\n\n
You may also control how Meta and other parties display certain ads to you, as explained further in their respective privacy policies and ad preferences pages. You can also obtain more information about targeted advertising, and how to opt-out of receiving targeted ads from many ad networks (including Meta and Google), \u00a0(Digital Advertising Alliance) and\u00a0\u00a0(Network Advertising Initiative).<\/p>\n\n\n\n
Opting out of participating ad networks does not opt you out of being served advertising altogether. You may continue to receive generic or contextual ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. Please note, that opt-out mechanisms are cookie based; so, if you use another device or browser, your opt-out may no longer be effective.<\/p>\n\n\n\n
Do-Not-Track Signals<\/strong><\/p>\n\n\n\n
We have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control (“GPC”) within the browser, with the exception of Strictly Necessary cookies. Please note that due to technical limitations, the GPC signal is only honored within a particular browser you are using. \u00a0The \u201cDo Not Track\u201d privacy preference may be available in some web browsers. It allows you to opt-out of tracking by websites. We try to honor Do Not Track settings; we may not be able to respond to all user settings or signals. \u00a0For more information about do-not-track signals, please click\u00a0here<\/strong>. You may also disable certain tracking as discussed above (e.g. by disabling cookies).\u00a0<\/p>\n\n\n\n
7. \u201cSelling\u201d or \u201cSharing\u201d of Consumer Personal Information<\/h2>\n\n\n\n
\u201cSale\u201d of Your Personal Information for Monetary or Other Valuable Consideration<\/strong><\/p>\n\n\n\n
We do not sell Personal Information as the term \u201csell\u201d is commonly understood to require an exchange for money. However, certain disclosures of Personal Information to third parties may be considered a \u201csale\u201d of Personal Information as the term \u201csale\u201d may be broadly defined to include both monetary and other valuable consideration. Using this broad definition, our \u201csale\u201d is limited to the following:<\/p>\n\n\n\n
– Our use of third-party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our websites; and<\/p>\n\n\n\n
– Our disclosure of your Personal Information to other third parties for the purposes described in Section 3 above.<\/p>\n\n\n\n
Our \u201csales\u201d of your Personal Information in this matter is subject to your right to opt out of those sales (see Section 9 below). Privacy laws may prohibit third parties who obtain Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt out of further sales.<\/p>\n\n\n\n
\u201cSharing\u201d of Your Personal Information for Cross-Context Behavioral Advertising<\/strong> <\/p>\n\n\n\n
We may \u201cshare\u201d your Personal Information for the purpose of cross-context behavioral advertising, subject to your right to opt out of that sharing (see Section 9 below). Our \u201csharing\u201d for the purpose of cross-context behavioral advertising is limited to the following:<\/p>\n\n\n\n
– Our use of third-party advertising cookies and their use in providing you cross-context behavioral advertising (i.e., advertising on other websites or in other mediums); and<\/p>\n\n\n\n
– Our disclosure of your Personal Information to parties for the purposes described in Section 3 above. <\/p>\n\n\n\n
When the recipients of your Personal Information disclosed for the purpose of cross-context behavioral advertising are also permitted to use your Personal Information to provide advertising to others (such as in the case of our use of third-party advertising cookies), we also consider this disclosure as a \u201csale\u201d for monetary or other valuable consideration under applicable privacy laws.<\/p>\n\n\n\n
Third Party Recipients<\/strong><\/p>\n\n\n\n
In the preceding twelve (12) months, we may have \u201csold\u201d for monetary or other valuable consideration, or \u201cshared\u201d for the purpose of cross-context behavioral advertising, the following categories of Personal Information to the following categories of third parties: <\/p>\n\n\n\n
A. Identifiers:<\/strong> We may sell and share this category of Personal Information for advertising and analytics purposes to the following categories of third parties: service providers; data brokers; authorized retailers; advertisers and advertising networks; social media companies. <\/p>\n\n\n\n
B. Commercial information: <\/strong>We may sell and share this category of Personal Information for advertising and analytics purposes to the following categories of third parties: service providers; data brokers; authorized retailers; advertisers and advertising networks; social media companies.<\/p>\n\n\n\n
C. Internet or other similar network activity<\/strong>: We may sell and share this category of Personal Information for advertising and analytics purposes to the following categories of third parties: service providers; authorized retailers; advertisers and advertising networks; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services.<\/p>\n\n\n\n
D. Inferences drawn from other Personal Information: <\/strong>We may sell and share this category of Personal Information for advertising and analytics purposes to the following categories of third parties: service providers; data brokers; authorized retailers; advertisers and advertising networks; social media companies.<\/p>\n\n\n\n
Sale or Sharing of Personal Information of Minors Under the Age of 18<\/strong><\/p>\n\n\n\n
We do not have any actual knowledge that we \u201csell\u201d the Personal Information of minors under the age of 18 for monetary or other valuable consideration and we do not have any actual knowledge that we \u201cshare\u201d such Personal information of minors under the age of 18 for cross-context behavioral advertising without affirmative consent as required by applicable privacy laws. <\/p>\n\n\n\n
Right To Opt-Out of Sale and Sharing. <\/strong><\/p>\n\n\n\n
In addition to the above-stated rights, if you live in certain states, you may have the right opt out of the \u201csale\u201d of your Personal Information for monetary or other valuable consideration and of \u201csharing\u201d your Personal Information for the purposes of cross-context behavioral advertising. You may exercise your right to opt-out by doing the following:<\/p>\n\n\n\n
– For the \u201csale\u201d or \u201csharing\u201d through the use of third-party advertising and analytics cookies or other tracking technology, you may adjust your cookie preferences by visiting the \u201cCookies<\/strong>\u201d or \u201cCookie Settings<\/strong>\u201d link on the footer of the relevant Site.<\/p>\n\n\n\n
– For the \u201csale\u201d or \u201csharing\u201d through our disclosure of your Personal Information to other third parties, you may fill out the following online form\u00a0here<\/strong><\/a>.\u00a0<\/p>\n\n\n\n