Effective Date: August 31, 2019
WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
We collect personally identifiable information (“Personal Information”) from you if you provide it to us. The Personal Information we collect may include your:
- phone number;
- email address;
- credit card information;
- date of birth; and
- any other information that might be used to identify you by another person.
We may use this Personal Information for the particular purposes for which it was collected or provided, as well as to:
- communicate with you regarding our products, services, promotions and news releases;
- provide you with information that you request;
- improve our product and service offerings;
- consider your job application and communicate with you about your job application;
- administer a contest, promotion, survey, market research, focus group or other feature to provide you with the relevant products and services;
- analyze visits to our websites and learn about the interests of our visitors on a personal level to better understand their interests and needs;
- respond to investor-specific inquiries;
- facilitate your transactions; and
All of the above uses are considered “Services.” With respect to Personal Information covered by the Privacy Shield, as defined and discussed further below, we certify that we collect and process Personal Information solely to the extent such Personal Information is relevant in providing the Services. For our record keeping purposes, we may retain certain Personal Information that you provide in connection with commercial transactions; however, we will only retain the information for so long as it serves the purpose of providing the Services.
HOW DO WE COLLECT AND SHARE PERSONAL INFORMATION?
We engage other companies, including, without limitation, certain of our affiliates and subsidiaries, to perform tasks on our behalf (“Agents”). We may need to share with your Personal Information with, and may transfer your Personal Information to, such Agents in order to provide products or Services to you (for example, general contests, email campaigns and similar marketing events, and in connection with investor relations matters). Other types of Agents we may share Personal Information with include those providing services to support our business functions, like analyzing contest and campaign data. Certain other Agents collect Personal Information on our behalf. For example, we use Agents for our career portal. In this context, Personal Information is collected by our Agents for a specific purpose (e.g., applying for a position) and transferred to us expressly for that purpose. In all circumstances where an Agent collects data on our behalf, it is for the purpose of providing the Services described above. All of these Agents are bound by contract to refrain from using the Personal Information we collect from you for any purpose other than providing the service to us. We are liable under the Privacy Shield Principles (as defined below) for our Agents to process transferred Personal Information in a manner consistent with the Principles.
We do not sell or share the Personal Information we collect from you to any unrelated third parties (who are not Agents) so that they may send you commercial promotions or unsolicited offers for unrelated products or services. If you would like more information about our disclosure of your Personal Information to third parties, please contact us at firstname.lastname@example.org.
When we transfer Personal Information to countries other than the country where it was provided, we do so in compliance with applicable data protection laws, including, as applicable, the Privacy Shield Principles as described below. We may transfer Personal Information from persons outside of the United States (“U.S.”) to affiliates located either in the U.S. or otherwise; provided that transfers to the U.S. from the European Union (“E.U.”) or Switzerland will comply with the Privacy Shield Principles in all respects.
HOW DO WE GATHER DATA BY AUTOMATIC MEANS?
Sometimes we and/or our Agents use cookie technology, web beacons, and similar technologies on our website to enhance functionality and navigation for our visitors, and learn about the use and users of our website. In doing so, we analyze trends, administer our websites and gather information about our user base as a whole.
Information tracked through these mechanisms includes, but is not limited to, (1) your IP address, (2) the type of web browser and operating system being used, (3) the pages of the website you visit, (4) other websites you visited before visiting our website, and (5) your geographic location.
If you wish to disable cookies, refer to your browser help menu to learn how to do so. Please note that if you disable cookies, the website may not function as intended and you may not be able to use certain features of the website.
Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We and/or our Agents may use web beacons on our websites to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize our website and improve your experience on our website. We and/or our Agents may also include web beacons in HTML-formatted email messages to determine which email messages are opened.
HOW DO WE ENGAGE IN ADVERTISING AND WHAT ARE YOUR CHOICES?
WHAT ARE YOUR COMMUNICATION CHOICES?
You may sign-up to receive emails, newsletters or other communications from us. If you wish to discontinue receiving this information, you may update your preferences by using the “Unsubscribe” link found in the emails that we send to you or by contacting us at
HOW DO WE RESPOND TO “DO NOT TRACK” SIGNALS?
Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers.
- Residents of the EU or Switzerland: When our website receives a DNT code from the EU or Switzerland, except in the case of certain scenarios where a user actively and knowingly provides Personal Information (e.g. contact forms), our website will not track your use across multiple websites other than the affiliated websites listed at postholdings.com/certified, but other websites (including, without limitation, certain of our subsidiaries’, affiliates’ and third party providers’ websites) to which we link may continue to track you. When we receive web requests from a user from the EU or Switzerland who enables DNT by actively choosing an opt-out setting in their browser, we will also take reasonable efforts to disable tracking cookies/scripts (e.g. Google Analytics, Google Adwords, Facebook, Twitter and/or other third party scripts).
- All Other Users: At this time, we do not respond to browser DNT signals from places outside of the EU and Switzerland. We and other third parties, including our Agents, may collect information about your online activities over time and across different websites, including when you visit our website. You can learn about how to exercise choice regarding the collection of information about your online activities over time and across third-party website or online services by visiting http://www.aboutads.info.
We may, but shall not be required to, also process personal information submitted relating to individuals in the E.U. and/or Switzerland via other compliance mechanisms, including data processing agreements based on the E.U. Standard Contractual Clauses. Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”), and we are committed to responding promptly to inquiries and requests by the United States Department of Commerce for information relating to the Privacy Shield Principles.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
LINKS TO OTHER WEBSITES
ACCESSING AND CHANGING YOUR INFORMATION
You have the right to confirm our possession of your Personal Information and/or to access, amend or delete any Personal Information we hold about you, stop receiving communications from us, and prevent any further use of your Personal Information by us, by contacting us at email@example.com. If we are unable to satisfy your request, we will provide you with an explanation as to why such request cannot be honored. You also have the right to opt out of us using your Personal Information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. We will respond to reasonable requests in an appropriate timeframe as determined by the respective authority governing the use of the applicable Personal Information.
We will also contact users whose Personal Information is within the scope of the Privacy Shield Principles to obtain prior affirmative express consent if sensitive Personal Information (i.e., Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or Personal Information specifying the sex life of the individual) is to be disclosed to a third party, or if such sensitive Personal Information is to be used for a purpose other than those for which it was originally collected or subsequently authorized by such user. We will treat as sensitive any Personal Information received from a third party where the third party identifies and treats it as sensitive.
This website is not directed to children under age 13, and we have no intention of collecting information from children under age 13, via this website or otherwise.
All matters relating to this website are governed by the laws of the State of Missouri, U.S.A. If you are located outside of the U.S. and you contact us, please be advised that any information you provide to us will be transferred to us in the U.S. and that by submitting information, you hereby explicitly authorize and consent to its transfer to the U.S.
HOW WE PROTECT PERSONALLY IDENTIFIABLE INFORMATION
We maintain reasonable and appropriate security measures designed to help protect against loss, misuse, and alteration of Personal Information collected by us. However, information transmitted on the Internet and/or stored on systems attached to the Internet is not 100% secure. As a result, we do not ensure, warrant or guarantee the security or integrity of such information. We will not be responsible for disclosure of any information due to errors in transmission or the unauthorized acts of third parties.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
PRIVACY SHIELD DISPUTE RESOLUTION
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your Personal Information. E.U. and/or Swiss individuals with inquiries or complaints regarding this policy should first contact our Privacy Officer at firstname.lastname@example.org.
We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider located in the U.S. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact the dispute resolution provider free of charge at https://feedback-form.truste.com/watchdog/request. Under certain limited circumstances, E.U. or Swiss individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
The FTC has committed to reviewing on a priority basis referrals alleging non-compliance with the Privacy Shield Principles received from independent dispute resolution bodies, among others. If the FTC concludes that it has reason to believe Section 5 of the Privacy Shield Principles has been violated, it may resolve the matter by seeking an administrative cease and desist order prohibiting the challenged practices or by filing a complaint in a federal district court, which if successful could result in a federal court order to same effect.
By email at email@example.com
By mail at 1699 S. Hanley Rd., St. Louis, MO 63144; Attn: Privacy Officer.
If you are a resident of a European country participating in the Privacy Shield and you believe we maintain your Personal Information within the scope of this Privacy Shield certification, you may direct any questions or complaints to the Company’s privacy officer, whose contact information is below:
VP of Enterprise Applications & Chief Privacy Officer
By email at firstname.lastname@example.org
By mail at 1699 S. Hanley Rd., St. Louis, MO 63144 Attn: Privacy Officer
We are committed and required to respond to any of your inquiries on this issue within forty-five (45) days of receiving the complaint.