Effective Date: March 1, 2021
The W.K. Kellogg Foundation (“WKKF” or “we”) is an independent, non-profit private foundation that works with communities to create conditions for vulnerable children so they can realize their full potential in school, work and life.
2. What Personal Information Do We Collected?
We may collect the following Personal Information when you visit or use the WKKF Web Applications.
A. Personal Information that You Provide to Us
WKKF may collect Personal Information directly from you. This may happen in several ways:
- Register for an Account. You may provide us with Personal Information when you register for an account on the WKKF Portal or another WKKF Web Application. Such information may include, but is not limited to, your name, organization affiliation, postal address, phone number, email address, username, password, and preferred language.
- Pursue or Receive a Grant, Program-Related Investment or Contract. You may provide us with Personal Information when you explore, pursue or receive a grant, program-related investment or contract. Such information may include, but is not limited to, your name, title, organization, postal address, phone number, mobile number, email address, and tax ID number.
- Sign Up for Communications. You may provide us with Personal Information when you sign up for communications from WKKF. Such information may include, but is not limited to, your name, company or organization affiliation, postal address, email address, and phone number.
- Download Resources. You may provide us with Personal Information when you request to receive or download publications or other resources through the WKKF Web Applications. Such information may include, but is not limited to, your name, company or organization affiliation, postal address, email address, and phone number.
- Sign Up for Events. You may provide us with Personal Information when you sign up for our events, such as workshops, conferences, and webinars, either through the WKKF Web Applications, through our service providers, or offline. Such information may include your name, company or organization affiliation, postal address, email address, and phone number.
- Contact Us. You may provide us with Personal Information when you contact us directly with your inquiries or comments.
- Apply for a Job. You may provide us with Personal Information when you apply for employment with us through our WKKF Websites.
B. Information Collected from Third Parties
WKKF may also collect information from certain third parties, such as Guidestar. Such information may contain information regarding your organization (e.g., its mission) and limited Personal Information (e.g., name of your organization’s executive director).
C. Information Automatically Collected by WKKF
If you visit the WKKF Web Applications, WKKF may automatically collect certain information from your device, such as the following:
- Your device type;
- Your IP address;
- Your usage and activity on the WKKF Web Applications (such as the pages you visit);
- Geographic and demographic data; and
- The amount of time you spend on the WKKF Portal.
This information may be collected automatically using cookies or log files. This automatic data is used for the administration of the WKKF Web Applications, for statistical analysis, to monitor the use or performance of the WKKF Web Applications, and to ensure that the content on the WKKF Web Applications is presented in the most effective manner for our visitors and users.
3. How Do We Use Personal Information?
We may use your Personal Information for the following purposes:
- to administer and provide the WKKF Web Applications;
- to develop, issue and administer WKKF grants, program-related investments, and contracts;
- to contact you in response to your inquiries, comments and suggestions;
- to provide other WKKF communications;
- to provide access to WKKF publications or other resources;
- to organize and manage our events;
- to administer and inform our program strategies and charitable activities;
- to manage our operations, including performing accounting, auditing, and other internal functions;
- to fulfill the purpose for which you provided the information;
- to comply with applicable laws and regulatory requirements, or as requested by government or regulatory authorities;
- in connection with pending litigation;
- to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
- to protect and defend the rights or property of WKKF;
- to improve the WKKF Web Applications and WKKF’s related processes, and to help WKKF understand how users are using the WKKF Web Applications and interacting with WKKF;
- in connection with a merger, divestiture, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred; and
- for tracking and analytics purposes described in the “Third Party Analytics Providers” section below.
4. How Do We Share Personal Information?
We may share your Personal Information with the following third parties:
- with our service providers that host the WKKF Web Applications, such as Fluxx Labs Inc.;
- with our other vendors, consultants and service providers that provide services on our behalf, such as translators, evaluators, technology platform providers and data hosting providers; and
- with third parties in connection with the uses described in Section 3 above, such as with government or regulatory authorities in order to comply with laws.
In addition, in connection with grants and program-related investments that we award, we may share your organization’s information generally on our WKKF Websites, such as in a profile regarding your organization and its mission, in our annual report, and in other publications.
5. Email Communications
If you have signed up to receive newsletters or other communications from WKKF, you may, at any time, inform us that you do not want WKKF to send you such communications by opting out using the link at the bottom of each email. After opting out, you will no longer receive communications from the mailing list from which you opted out; however, you may still receive transactional or other communications from us (e.g., communications regarding a grant, program-related investment or contract).
6. Review and Correction of Personal Information
You may review, correct, and update certain Personal Information by contacting us through the “Contact Us” section below.
7. Safeguarding Your Information
WKKF cares about the security of your Personal Information. However, the Internet is a global communications vehicle open to threats, viruses, and intrusions from others. For this reason, WKKF cannot promise, and you should not expect, that we will be able to protect your Personal Information at all times and in all circumstances. WKKF cannot guarantee the security and privacy of transmissions via the Internet, and we will not be liable for any lack of security relating to the WKKF Web Applications or any other communication over the Internet. To the maximum extent permitted by applicable law, WKKF shall not be liable for any damages resulting from any loss of privacy or security occurring in connection with any such communications.
8. Third Party Analytics Providers
A. Do Not Track Disclosure
Certain web browsers may provide an option by which you may ask your browser to inform websites you visit that you do not wish your activities to be tracked by cookies or other persistent identifiers, commonly called “Do Not Track Signals.” The WKKF Web Applications currently do not respond to Do Not Track Signals.
B. Third Party Analytics Providers; Google Analytics; Kissmetrics
We work with third party analytics service providers, including but not limited to Google Analytics and Kissmetrics, to help us better understand how our users use the WKKF Web Applications. As a result, these third parties may collect certain information from you about your online activities over time and across different websites when you use the WKKF Web Applications.
We use Google Analytics to learn more about the types of users that visit the WKKF Web Applications and to help improve the WKKF Web Applications. Google Analytics provides us with certain data regarding the demographics of the users that visit the WKKF Web Applications and their activities on the WKKF Web Applications. To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/.
You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.
9. Third Party Websites
11. Children Under 16
We do not seek to collect, nor do we knowingly collect, information from children under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. To do so, contact WKKF through the information provided below in the “Contact Us” section.
12. Other Disclosures
Per requirements of the Transparency in Coverage final rule, the machine readable files (MRFs) for the group health plan(s) associated with W.K. Kellogg Foundation can be found at www.meritain.com.
13. Contact Us
By Postal Mail:
Office of the General Counsel
W.K. Kellogg Foundation
One Michigan Avenue East
Battle Creek, MI 49017
By E-mail: firstname.lastname@example.org
By Phone: 269-968-1611
INTERNATIONAL DATA PROTECTION RIGHTS
The laws of several countries, including and those in the United Kingdom and the European Union, grant their residents additional rights regarding use of their personal data as defined under those laws. The following sections provide additional information regarding WKKF’s use of personal data of certain international residents and certain of those individuals’ rights, which will vary by country, with respect to their data where such laws apply.
Legal Basis and Purposes for Data Processing.
We only process your personal data when we have a legal basis for doing so, as recognized by the laws of the country of your residence. Specifically, we will only process your personal data where at least one of the following applies:
- Where our use of your personal data is necessary to perform a contract or contracts that you are a party to, or to take steps that you request before entering a contract. For example, to facilitate the consideration, administration, or execution of a grant or vendor agreement;
- Where our use of your personal data is within our legitimate interests or the legitimate interests of the organization with which we have shared your personal data and we have made sure that your personal data, and your rights in relation to that information, are protected. For example, to correspond with you regarding current or future WKKF programs and opportunities in connection with your prior or ongoing relationship with WKKF;
- Where we believe it is necessary to use your personal data to comply with a legal or regulatory obligation.
- In limited circumstances where we believe it is necessary to protect someone’s safety or vital interests;
- In certain circumstances, we may need to use your personal data for purposes which are in the public interest; and
- Where we have your consent. We will rely on your consent, for example, to use your personal data for marketing to you by email and text message. Where we rely on consent to use your personal data, you have the right to withdraw that consent at any time. Please see the ‘Your rights’ section of this notice for more details.
Automated Decision Making and Profiling.
We do not make automated decisions about you or engage in data profiling.
Personal Information Requirements.
You are not required to provide any personal data to WKKF. To apply for funding, provide services, apply for employment, or otherwise engage with WKKF, you may be required to provide certain personal data. During any required registration for our services or products, you will be provided with information regarding which data elements are required.
You have choices regarding how we use your personal data. Depending on your country of residence, you may be entitled one or more of the following. As a precondition to exercising these rights, we must receive a verifiable request from you demonstrating that you reside in a jurisdiction granting you such rights under your country’s applicable law.
- The right to access: The right to request copies of your personal data. We may charge you a minor fee for this service.
- The right to rectification: The right to request that we correct any personal data that you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete.
- The right to erasure: The right to request that we erase your personal data under certain conditions.
- The right to object to processing: The right to object to our processing of your personal data, under certain conditions.
- The right to data portability: The right to request that we transfer the personal data we have collected to another organization, or directly to you, under certain conditions.
- The right to opt-out or limit processing: The right to request that we cease processing certain of your personal data in whole or in part, for specified purposes to the extent required under applicable law.
- The right to not be subject to automated decision-making: The right to request that we not use your personal data for the purpose of generating automated decisions or individual profiles that have a legal impact on you.
- Opt-in rights: Subject to certain exceptions, if you are a resident of certain countries, including Argentina, Australia, Canada, Colombia, South Africa, or any country within the United Kingdom or the European Union, we must have your consent to process sensitive data about you (as defined in your country’s data privacy legislation).
In certain instances, we may receive your personal data from third parties. If WKKF is processing your personal data as a data processor, we will refer you to the data controller for assistance with these requests. We support our data controllers with responding to requests required by law.
You may also decline our marketing communications or ask us to revoke your consent for data collection.
To exercise these rights, please contact us via email to email@example.com or write to the address above. Note that for your protection, we may need to verify your identity before we can process your request.
If you believe that we have violated applicable law in our processing of your personal data, please contact us by e-mail at firstname.lastname@example.org, by telephone at 269-968-1611, or contact a supervisory authority.
Your personal data will be retained for as long as the information is needed for the purposes set forth above and for any additional period that may be required or permitted by law. The retention period depends on the purpose(s) for which the data was collected, how it is used, and applicable law. You may request that we delete your personal data by contacting us via email at email@example.com or writing to us at the address above. If we do not have a legal basis for retaining your information, we will delete it as required by applicable law.
CHANGES TO OUR PRIVACY STATEMENT
It is our policy to post any changes we make to our privacy statement on our site. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the site home page. The date the privacy statement was made effective is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our site and this privacy statement to check for any changes. Your continued use of the WKKF Web Applications or any products, services, or solutions following the posting of changes constitutes your acceptance of such changes.
If you have questions regarding this privacy statement or our data privacy practices, or if you believe we may have violated applicable law, please contact us by firstname.lastname@example.org or by telephone at 269-968-1611.