How General Mills lures consumers online-- its new "you can't sue us" policy a digital bait and switch/FTC must review

General Mills has changed its privacy policy (link is external) to say, according (link is external) to the New York Times, so consumers now “give up their right to sue the company if they download coupons, “join” it in online communities like Facebook, enter a company-sponsored sweepstakes or contest or interact with it in a variety of other ways.Instead, anyone who has received anything that could be construed as a benefit and who then has a dispute with the company over its products will have to use informal negotiation via email or go through arbitration to seek relief, according to the new terms posted on its site.”

General Mills uses a wide range of digital media, including Facebook (link is external), mobile marketing (link is external), apps, (link is external) digital discount (link is external)coupons, contests (link is external) to help schools (Boxtops for Education), YouTube (link is external), Twitter, (link is external) specialized “target” marketing to Hispanics (link is external) and more as part of its marketing campaigns. Is it now saying that if a consumer wants to take advantage of any of the online offers that General Mills deliberately promotes, they must give up their consumer rights?

And have you looked at its privacy (link is external)policy, where even teens can be targeted online, and which acknowledges that its partners may track you using behavioral eavesdropping tactics? However, this incident helps to uncover how food marketing companies are engaged in largely stealth digital tactics that unfairly collect our information, including from young people. Here are key and revealing excerpts from the General Mills privacy policy:

Information we collect We may collect information about you (and the computer or device you use to access our Site) in a variety of ways:

You may directly provide information to us You may choose to allow a social networking service to share information with us We may gather other information when you visit our Site or other services, or when you view our online ads We may obtain additional information about you from other sources where permitted by law…

Information from social networking services If you choose to access or make use of third-party social networking services (such as Facebook or Twitter), we may receive personal information about you that you have made available to those services, including information about your contacts on those services. For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on our Site. Some social networking services also will facilitate your registration or log-in for our Site or enhance or personalize your experience on our Site. Your decision to use a social networking service will always be voluntary. However, you should make sure you are comfortable with the information social networking services may make available to our Site by visiting those services’ privacy policies.

Information we gather when you visit our Sites, or when you view our online ads When you visit or use our Sites, or when you view our online ads, we may use cookies, web beacons, or other technologies to collect information about your computer or device and your online activity. The following are examples of the types of information we may collect in this way:

Device type (such as desktop, tablet, or mobile device) Browser type (such as Internet Explorer) Operating system (such as Windows) IP address, MAC address, device ID, installed fonts, or similar information Websites or online services you visit before or after our Site Your interaction with our Site (such as the links you click and the pages and items you view) Whether you open or forward our emails or click on elements within these emails

Information we may obtain from other sources We may obtain information about you from other sources, such as public databases, other brands and groups within General Mills, data aggregators, and other commercially available sources. This information may include:

Name Email address Social networking user IDs Postal address Phone number Age Gender Demographic information Marital status and number and age of children Income level Purchasing behavior Interests, hobbies, and product preferences Interactions with media or advertising Publicly observable activities (such as blogs and online postings) Other information that has been collected by other brands or businesses within the General Mills family of companies…

Cookies used for online behavioral advertising – and your choice to opt out Third parties that are involved in serving other companies’ advertising on our sites, or that are involved in determining which advertisements to show you on third-party websites, may use cookies to collect information about your online activities, such as the advertisements you have seen or the websites or pages you have visited, in order to draw inferences about what advertising might be relevant to you.

These third parties may use the information gathered through these cookies to show you advertising they believe to be most relevant to you when you visit other websites not belonging to us. This practice is called “online behavioral advertising.” You have the ability to opt out of allowing these third parties to use cookies for online behavioral advertising by clicking here (link is external).