Effective Date: May 26, 2021

At Post Holdings Partnering Corporation (“Post” or “we” or “our”), we want you to be familiar with how and why we collect, use and disclose information about you. This includes information we collect through our website, https://www.postpspc.com (the “Site”) and in connection with the operation of our business. Some of this information may individually identify you. This Privacy Policy explains our information practices with respect to information collected and the choices you can make about the collection, access and use of your information.

We are committed to safeguarding your privacy and ensuring that your information is protected. As part of our commitment, we train our employees about the importance of privacy and how to handle and manage information appropriately and securely.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

We collect personally identifiable information (“PII”) from you when you voluntarily provide it to us, including through a number of features/activities available on the Site. For instance, we may collect PII when you:

  • contact us through the Site;
  • ask to receive information from us such as press releases or company information;
  • otherwise participate in features of the Site that ask for personally identifiable information; or
  • become our stockholder or investor in Post.

The PII that we collect may include your:

  • first and last name;
  • mailing address;
  • email address; and
  • any other information that might be used to identify you by another person.

We will use this PII for the purposes for which it was provided/collected and to:

  • communicate with you regarding our company and news releases;
  • record and manage our stockholders and provide you with information about our stock, stockholder meetings, and operation and business of our company;
  • provide you with information that you request;
  • improve our Site and offerings;
  • analyze visits to our Site and learn about the interests of our visitors on a personal level to better understand their interests and needs;
  • facilitate your transactions; and
  • communicate with you regarding our Site, Privacy Policy and Terms of Use (the above uses, collectively, the “Services”).

There are additional disclosures for California residents in the CALIFORNIA PRIVACY RIGHTS section below.

For our record keeping purposes, we may retain certain PII that you submit in conjunction with transactions.

If you no longer wish to receive emails from us, you have the opportunity to unsubscribe from receiving emails from us via the “unsubscribe” link in the emails we send or by contacting us at https://www.postpspc.com/contact-us.

HOW DO WE SHARE PERSONAL INFORMATION?

We engage other companies, including, without limitation, certain of our affiliates and other entities (“Agents”), to perform certain services on our behalf. We may need to share, and may transfer, your information with them in order to provide the Services to you. Other types of Agents with which we may share PII include organizations providing services to support Post functions. Certain other Agents collect PII on our behalf. Pursuant to written agreements with these Agents, which agreements afford appropriate, and all required, protections of your PII, we use these Agents to provide the following services on our behalf:

  • email services;
  • legal representation, including with regard to prevention harm to our company, its affiliates, our or their products or services, or a person or property (e.g., fraud prevention); and
  • stockholder record-keeping, notice, transfer agent and other investor relation services.

All of our Agents are bound by contract to refrain from using your PII for any purpose other than providing the applicable service to us.

We also reserve the right to share information within the family of companies owned by our parent company, Post Holdings, Inc.

In addition to disclosures described above, we may disclose or transfer PII in connection with, or during negotiations of, any merger, share exchange, asset acquisition, share purchase, reorganization or similar partnering transaction. We may also disclose PII to prevent damage or harm to us, our Services or any person or property, if we believe that disclosure is required to meet national security or law enforcement requirements, or in response to a lawful request by public authorities.

Post does not sell or share the PII it collects 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 PII to third parties, please contact us at https://www.postpspc.com/contact-us.

California residents may have additional rights and choices regarding your PII. Please see the CALIFORNIA PRIVACY RIGHTS section below for more information.

HOW DO WE GATHER DATA BY AUTOMATIC MEANS?

We (and third party service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our Site. Cookies are files that store information on your computer hard drive or browser that mean that we can recognize that you have visited us before. We use cookies and similar technologies to enhance functionality and navigation for our visitors, and learn about the use and users of our Site. In doing so, we analyze trends, administer our Site and gather information about our user base as a whole.

Information tracked through these mechanisms includes, but is not limited to, (1) cookies placed on the browser or user by Google in the last 6 months; (2) the number of clicks or touches on the Site, (3) the CSS information for the pages viewed; (4) the date; (5) the language selected for the browser (6) plug-ins installed on the browser; and (7) Javascript objects.

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 Site may not function as intended and you may not be able to use certain features of the Site. Our Cookie Policy is available here https://www.postpspc.com/cookie-policy.

LINKS TO OTHER WEBSITES

Our Site may contain links to the websites of our affiliates and to websites that are owned and operated by third parties. These other websites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of websites owned and operated by any such third parties. Other websites may collect and treat information collected differently.

CHILDREN’S PRIVACY

The Site is not directed to children under age 16, and we have no intention of collecting information from children under age 16, via the Site or otherwise.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of this Site that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to privacyinquiries@postholdings.com or by mail to Post Holdings Partnering Corporation at 2503 S. Hanley Rd., St. Louis, MO 63144.

We collect information that constitutes “personal information” as the same is defined and protected under the California Consumer Privacy Protection Act (the “CCPA”) because we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device. In particular, we have collected the following categories of personal information (as defined in the CCPA) from California residents or devices (whether directly, indirectly (e.g., by observing your actions on the Site) or from third parties) within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

For the purposes of this Section and our compliance with the CCPA, “personal information” does not include publicly available information from government records, deidentified or aggregated consumer information or information specifically excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data or other information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In the preceding twelve (12) months, Post has disclosed the following categories of personal information (as defined under the CCPA) for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category F: Internet or other similar network activity

to the following categories of third parties:

  • email service providers;
  • legal representation, including with regard to prevention harm to our company, its subsidiaries, our products or services or a person or property (e.g., fraud prevention); and
  • stockholder record-keeping, notice, transfer agent and other investor relation service providers.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

  • Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (please see Subsection Exercising Access, Data Portability, and Deletion Rights below for more information), we will disclose to you:
    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you (also called a data portability request).
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      • sales, identifying the personal information categories that each category of recipient purchased; and
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (please see Subsection Exercising Access, Data Portability, and Deletion Rights below for more information), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.


    We may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:

    • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through one of the following:

    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

    Making a verifiable consumer request does not require you to create an account with us.

    We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

  • Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.

    If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

    Any disclosures we provide will only cover the twelve (12)-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  • No Personal Information Sales. We do not sell any personal information that we collect or use.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

HOW WE PROTECT PERSONAL INFORMATION

Post maintains reasonable and appropriate technical and organizational security measures designed to help protect against loss, misuse, and alteration of PII collected and processed by Post. 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.

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. When our Site receives a DNT code, except in the case of certain scenarios where a user actively and knowingly provides PII (e.g. contact forms), our Site will not track your use across multiple websites, but other websites (including, without limitation, certain of our affiliates’ and third party providers’ websites) to which we link may continue to track you. When we receive web requests from a user who enables DNT by actively choosing an opt-out setting in their browser, we will take reasonable efforts to disable tracking cookies/scripts (e.g. Google Analytics, Google Adwords, Facebook, Twitter, and/or other third party scripts).

GOVERNING LAW

The Site is intended for use by residents of the United States only. All matters relating to the Site and this Privacy Policy are governed by the laws of the State of Missouri, U.S.A. Please be advised that any information you provide us will be transferred to the United States and by submitting such information, you explicitly authorize such transfer.

CHANGES IN OUR PRIVACY POLICY

We may amend this Privacy Policy at any time. If we make any material changes in the way we collect, use, and/or share your PII or to this Privacy Policy, we will notify you by prominently posting notice of the changes on the Site. We encourage you to periodically review this page for the latest information on our Privacy Policy.

YOUR CONSENT TO THE TERMS OF THIS PRIVACY POLICY

By using our Site, you acknowledge that we are processing your PII in accordance with this Privacy Policy. If you do not wish that we process your PII in this way, please do not use our Site or otherwise provide us with your PII.

By using the Site, you signify your assent to the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use the Site or submit any PII to us.

CONTACT US

By telephone at 844-931-2041

By email at privacyinquiries@postholdings.com

By mail at 2503 S. Hanley Rd., St. Louis, MO 63144.