U.S. Privacy Notice
Last Modified October 1, 2023
Scope
In this privacy notice (“Notice”), Mondelez Global Direct Inc. (“Mondelēz Global”, “we”, “our”, “us”), we describe our collection, use, and disclosure of the personal information that we collect about you through our websites, including Clifbar.com, mobile applications, or cloud-based services and communication platforms with a link to this Privacy Notice (collectively, “Sites”) and the products and services available through our Sites, and interactions with you (our “Services”). This Notice does not apply to Clif Bar 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 “personal information” in this Privacy Notice means information that identifies or can reasonably identify users of the Site (“you”) personally. If you are a California resident, please see Additional Information For California Consumers below for additional disclosures.
Personal Information We Collect About You
We collect the following information directly from you, about you from other sources, and automatically as you use our Services and Sites.
Name, Contact Information and Identifiers: We collect identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Customer Management and Support Records: We collect information when you contact us with an inquiry regarding our products and Services, such as your name, email address, postal address, or phone number, and your comments or inquiry. If you call our customer service hotline, we may keep an audio or electronic recording or transcript of your call with our customer support specialist for quality assurance purposes. If you have an account with us, however, we do not typically associate this recording or transcript with your account. We collect credit card information for billing and transactional purposes in connection with providing you our products and Services, this information may be considered sensitive personal information in California, for more information, please see please see Additional Information For California Consumers.
Purchase History and Tendencies: We collect commercial information including records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Newsletters and E-Mail Sign-up: In some of our Sites, you may sign-up for our newsletter using your email address. You may unsubscribe from receiving our newsletter at any time by opting out in the email or manage your preferences as described in the Marketing, Advertising and Communications section below.
Content: When you submit comments, ratings, and other content (collectively “content”), we maintain a copy of this content. We may collect certain metadata associated with the content (e.g., location, date/time stamp, device type). For certain types of posting, including reviews, we may require you to provide an email address to us before you may post the review.
Surveys and Web Forms: We collect information from you when you fill out web forms on our Sites or participate in one of our surveys.
Other Information We Collect About You: We may also collect personal information about you through our social media pages (for example, if you post a comment about one of our products) but we do not typically combine this information we learn about you with other information we hold about you.
Information we Collect from Other Entities: We also collect information from other sources such as our data analytics service providers and advertising providers. We may combine the information we receive from and about you on- and offline, including personal and non-personal information collected through our Sites, to help us tailor our communications to you and to improve our Sites and Services.
Information We Collect Automatically: We and the parties we work with and who help us to place and manage our advertisements may use cookies, web beacons, pixel tags, log files, or other technologies to collect certain information about visitors to and users of our Sites to deliver online advertisements that we think would be more relevant to your interests. We also use such data to monitor your interactions with our emails, text messages and online advertisements. For example, we automatically collect certain information from you, such as the type of web browser and operating system you use, the name of your Internet Service Provider, Internet Protocol (“IP”) address, software version, geolocation information and the domain name from which you accessed our Sites. In addition, we may collect information about your browsing behavior, such as the date and time you visit our Sites, the areas or pages of our Sites that you visit, the amount of time you spend viewing or using our Sites, the number of times you return to our Sites, other click-stream or site usage data, emails or ads that you open, forward or click-through to our Sites. Collecting this information, and linking it with other personal information we collected about you, helps us best tailor our Sites and enhance your online experience by saving your preferences while you are visiting our Sites, and to help us identify Sites features, advertisements, and offers that may be of particular interest to you.
How We Use Your Personal Information
We collect, use, disclose, and otherwise process your information, including your personal information, for the following purposes:
Provide and Improve our Services, Customer Services and Support Purposes:
- 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 address problems and review the usage and operations of our Sites and Services or business.
Marketing, Advertising, and Communications:
- Where permitted by applicable law, to contact you with information, newsletters, and promotional materials, including special offers promotions 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 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;
Analytics and Research:
- For research and analytic purposes, such as to understand usage and activity trends and other statistical purposes, such as what products are most popular.
- To create a profile about a consumer reflecting the consumer’s 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.
Protecting Company Rights, Security, and Interests:
- 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.
- To detect, prevent, or otherwise address fraud, security, or technical issues.
- To prevent or stop activity that we consider to be, or poses a risk of being, an illegal, unethical, or legally actionable activity.
- To use as evidence in litigation.
- To enforce this Notice or Terms of Use.
Legal Compliance:
- To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding.
- To respond to a subpoena, warrant, court order, or other legal process.
- As part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
When We Disclose Your Personal Information
We disclose your personal information in the following ways:
Other Users
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, 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.
Affiliates & Service Providers
We may disclose personal information among our brands, affiliates, parent companies 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.
Marketing Partners
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’t want us to disclose your personal information to our marketing partners, you may opt-out by contacting us here. However, if you opt-out of such marketing, this won’t affect information we have already disclosed about you, and we may still send you our own marketing and promotional emails about information and ads we think you may be interested in (unless you have opted-out of receiving marketing emails from us).
Legal Compliance and Protecting Rights and Interest
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, or our security, the Services, any third party, 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.
Business Transfers
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.
Aggregate and De-Identified Information
We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
Online Advertising
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 “your ability to control cookies and similar technologies section” below.
Custom Audiences and Matching
We may disclose certain information (such as your email address) to other parties – such as Facebook (more info on Facebook Custom Audience here) so that we can better target ads and content to our users, and others with similar interests on these external platforms or networks (“Custom Audiences”). 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, contact us here and we will opt you out of our future Custom Audiences.
Interest-based Ads
We work with others (“ad companies”) 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’s 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.
How You Can Control Cookies
You may control how Facebook 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 Facebook and Google), through the following: optout.aboutads.info/ (Digital Advertising Alliance) and optout.networkadvertising.org (Network Advertising Initiative).
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 delete cookies, block cookies or use another device, your opt-out will no longer be effective.
Manage your cookie settings here:
Do-Not-Track Signals
Our Site does not respond to do-not-track signals, except in the context of Global Privacy Control (“GPC”) via web beacons. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed above (e.g. by disabling cookies).
Analytics
We may use analytics companies, for example Google Analytics (see privacy policy and opt-out), 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.
Links and Social Plug-Ins
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.
Security
Protecting your personal information is important to us. We maintain administrative, technical, and physical safeguards designed to help protect against unauthorized use, disclosure, alteration, or destruction of the personal information we collect on our Sites. However, no data security measures can guarantee 100 percent against compromise.
Children’s Privacy
We do not knowingly collect any personal information from children under the age of 13. If we discover that a child under 13 has provided us with personal information, we will endeavor to delete such personal information from our systems.
Changes To This Notice
We may from time- to- time change or update portions of this Notice in accordance with applicable laws. Please check back periodically so you are aware of any changes or updates to the Policy. We will indicate the Notice 's last updated date at the top of this Notice. We will post any changes to this Notice on our Site and will take steps to notify You of material changes, such as via email or prominent notice on the Site.
Contact Us
If you have any questions about this Notice, you can contact us at:
Mondelez Global Direct Inc.
100 Deforest Avenue
East Hanover, NJ 07936
Attention: Legal Department
Additional Information For California Consumers
Under the California Consumer Privacy Act (“CCPA”), as amended by the Consumer Privacy Rights Act (“CPRA”), we are required to provide specific disclosures about how we use and disclose personal information (“California Personal Information”) about you (“consumers” in this section). This section covers how we have collected, used, disclosed and otherwise processed your California Personal Information over the past 12 months, as well as additional rights you may have with respect to your California Personal Information. This section does not reflect our processing of California Personal Information where an exception under California law applies.
California Personal Information
Depending on your online and offline interactions with us, we may collect and process for purposes described in the “When We Disclose Your Personal Information” section above the following categories of California Personal Information:
- Identifiers: including contact details such as real name, postal address, email address, account name, or other similar identifiers;
- Financial Information: including credit card information;
- Customer Records: paper and electronic customer records containing Personal Information, such as name, address, telephone number;
- Purchase History And Tendencies: commercial information including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or Other Electronic Network Activity Information: including your interactions with our Sites;
- Audio, Electronic, Visual, or Similar Information: audio, electronic, visual, or similar information (but note that we do not sell this information). For example, if you contact our call center, we may retain a copy of that call recording.
- Inferences: drawn from the information collected.
Certain California Personal Information that we collect about you may be considered Sensitive Personal Information within the meaning of California Privacy Law, including: credit card information which we collect for billing and transactional purposes in connection with providing you our products and Services. Clif Bar only uses and discloses Sensitive Personal Information as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.
Sources
We collect the categories of California Personal Information identified above directly from you, automatically as you use our Sites and Services, and from third parties such as data analytics providers, social media networks, and distributors and intermediaries.
Purposes of Use
We use California Personal Information for the following business and commercial purposes:
| Business Purposes | Commercial Purposes |
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Disclosure of California Personal Information
- We may disclose the categories of California Personal Information described above for the business purposes described above to:
- Third-party service providers and contractors that perform data processing activities on our behalf, subject to appropriate privacy and security obligations;
- Customers, distributors, and intermediaries in connection with the performance of transactions;
- Government and other authorities as required by law;
- Potential purchasers and other parties in connection with the sale, purchase or merger of a business; and
- Others to the extent necessary to comply with applicable law and as otherwise permitted under California Privacy Law.
- We may disclose Identifiers and Internet or Other Electronic Network Activity Information for the commercial purposes described above to:
- Third-party service providers; and
- Social media and advertising networks
Your California Privacy Rights
Subject to certain exceptions detailed in California Privacy Law, as a California resident, you have the right to request: (i) deletion of your California Personal Information; (ii) correction of inaccurate California Personal Information; (iii) the right to know/ access the categories of California Personal Information that we collect about you, including the specific pieces of California Personal Information; (iv) the categories of California Personal Information disclosed for a business purpose; and (v) information about the categories of California Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the California Personal Information was shared.
In addition, California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell or Share My Personal Information
In addition to the above-stated rights, California residents have the right to opt-out of the selling or sharing of their California Personal Information, as such terms are defined under California Privacy Law. To exercise this right, please click here.
In addition, we have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control ("GPC") within the browser. Please note that due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our Sites.
We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon your exercising your rights under applicable law.
Finally, we do not “sell” or “share” California Personal Information about consumers that we know are younger than 16 years old without opt-in consent.
Exercising Your Rights
If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the California Personal Information collected or shared with third parties, please call us at 1-800-CLIFBAR (1-800-254-3227) (toll free), or you can submit your request online by using our Individual Rights Request Form. When submitting your request, please include the specific nature of your request, referencing "Your California Privacy Rights," as well as your first and last name, email address, and zip code or mailing address. Clif Bar may apply any exceptions or other conditions available under law when responding to access, correction, deletion, or other requests. Clif Bar will generally fulfill requests for access, correction, and deletion within 45 days of receiving a valid verified request. Clif Bar may extend the respond time by another 45 days by notifying the individual of the time extension.
Authorized Agents
To the extent that you elect to designate an authorized agent to make a request on your behalf, the authorized agent must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of the agent’s identity; a valid, designated power of attorney as defined under the California Probate Code, and certificate of registration as an agent before the California Secretary of State. If you are an agent submitting the request on behalf of a California consumer, please use our Individual Rights Request Form.
Financial Incentives
We offer our customers loyalty programs, as well as sweepstakes, contests, or similar promotional campaigns (collectively, "Programs") that allow participants to earn or otherwise receive discounts, rewards, and exclusive offers. Participation in these Programs is voluntary and requires your prior opt-in consent, which you may revoke at any time by following the instructions provided in such terms. Information collected via these programs may include email address and other contact information, demographic information, and opinions.
Because our programs involve the collection of personal information, they might be interpreted as a “financial incentive” under California law or as a "loyalty program" under other US state privacy laws. The value of your personal information to us is related to the value of the perks (e.g., discounts) provided in the Program less the expense related to offering those benefits to program participants.
Data Retention
We keep your California Personal Information for as long as needed or permitted according to the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) for the duration of a contract with you; (iii) as required by a legal obligation to which we are subject to; or (ii) as advisable considering our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). We may remove California Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete California Personal Information from our database at any time and without providing any reason.
Shine The Light
Separately, under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us their Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant sharing in the prior calendar year (so, requests submitted in 2020 would be applicable to relevant disclosures (if any) in 2019). If you are a California resident and would like to make such a request, please submit your request in writing by mailing us at Mondelez Global Direct Inc., 100 Deforest Avenue, East Hanover, NJ 079368, using the subject line "Request for California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address and email address. We will reply to valid requests by sending a response to the email address you included with your submitted request. Please note that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.
Prior versions of our Privacy Notice may be found here.