Privacy Notice

Personal data means any information that can be used to identify directly or indirectly a specific individual.

You are not required to provide Unilever the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

We may collect personal data from a variety of sources. This includes:

• Personal data you give us directly,
• Personal data we collect automatically, and
• Personal data we collect from other sources.

Personal data means any information that can be used to identify directly or indirectly a specific individual. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, sweepstakes and competitions and online through our websites, applications and branded pages on third-party platforms and applications accessed or used through third-party platforms.

You may be asked to provide your personal data when you are in contact with us. Hindustan Unilever Limited companies may share your personal data with each other and other Unilever Group companies and use it in a manner consistent with this Privacy Notice. We may also combine it with other information to improve our products, services, content, and advertising.

You are not required to provide Unilever the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.

 

Ways in which we collect your personal data

We may collect personal data from a variety of sources. This includes:

• Personal data you give us directly. We collect data about how you use our services and products, such as the types of content you view or engage with, or the frequency and duration of your activities. We also collect personal data you provide us when you sign up for a marketing newsletter, complete a survey or register for an account to buy our products. In so doing, we may ask for personal data, such as your name, gender, date of birth, address, email address, telephone number or credit card details. Some Unilever brands may collect “special categories of personal data” about you with your explicit consent. For more information on the special categories of data we collect and how we use it, please refer to the relevant section below.

·       Personal data we collect automatically. We also receive and store certain types of personal data whenever you interact with us online. For example, we use cookies and tracking technologies to obtain personal data when your web browser accesses our websites or advertisements and other content served by or on behalf of Unilever on other websites. You can read our Cookie Notice for greater detail on use of Cookies. Your personal data is also collected when you search, buy, post, participate in a contest or questionnaire or communicate with our customer service teams. Examples of the types of personal data we collect include; IP address, device ID, location data, computer and connection information such as browser type and version, time zone setting, browser plug-in types and versions, operating system, and purchase history – which Unilever sometimes aggregates with similar information from other consumers. During some of your internet browsing on Unilever’s websites we may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

• Personal data we collect from other sources. We collect personal data from other sources including our trusted partnerships with third-parties and where we operate Unilever accounts on third-party platforms: For example, when you use the “like” functionality on Facebook or the +1 functionality on Google+. Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data enrichment providers (to find out more see our privacy key terms) who may deliver insights to Unilever about the personal data we hold.

 

When and why we collect “special categories of personal data”

Certain categories of personal data, such as health data, financial data, biometrics, race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” or “Sensitive Personal Information” and benefit from additional protection.

We limit the circumstances where we collect and process these special categories of data.

Unilever sometimes collects data related to your health such as allergies, pregnancy or skin type to send you tailored ads and relevant promotions. Unilever only collects and uses this personal data where you have provided us with your consent for us to do so. In some instances, you may have requested services or products that do not directly involve the collection of any special categories of data, but may imply or suggest your religion, health or other special categories of data.

To illustrate circumstances where Unilever collects and processes special categories of data we have provided the following examples:

• Unilever collects expectant mothers’ due dates in its Zwitsal or Baby Dove newsletter sign-up page. It may also place cookies on the sign-up page which capture this information too. This data is then used to create an audience of expectant mothers to receive online advertising from relevant Unilever brands. For more information on Unilever’s profiling activities, please refer to the relevant section;

• Similarly, Unilever collects personal data related to consumers’ allergies to provide consumers with ads and promotions for products which are relevant to their needs.

We understand the importance of taking extra precautions to protect the privacy and safety of children using Unilever products and services.

Most of Unilever’s websites are designed and intended for use by adults. Where one of our websites is intended for use by a younger audience, we will obtain consent from the person with guardian responsibility before we collect personal data where it is required by applicable laws and regulations (the age at which consent is necessary varies from Country to Country).

If you are a child under the age where guardian consent is required in India, you should review the terms of this Privacy Notice with your parent or guardian to make sure you understand and accept them. If we discover that we have collected personal data from a child without consent from a parent or guardian where such consent should have been obtained, we will delete that personal data as soon as practical. Access to certain parts of the Unilever’s websites and/or eligibility to receive prizes, samples or other rewards are generally limited to users over a certain age.

We sometimes use your personal data to carry out age verification checks and enforce any such age restrictions.

We collect, process and disclose your personal data only for specific and limited purposes. For example, to process your payments, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised products, communications and targeted advertising as well as product recommendations to you.

We also create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.

Additionally, Unilever processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.

We collect, process and disclose your personal data for the following purposes:

• To process your payments, if you purchase our products, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;
• To process and answer your inquiries or to contact you to answer your questions and/or requests;
• To develop and improve our products, services, communication methods and the functionality of our websites;
• For the purposes of competitions or promotions that you have entered;
• To manage your account, membership in our programs, platforms or applications, including but not limited to ecommerce platforms, contests, loyalty/reward schemes, etc.
• To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
• To manage our everyday business needs regarding your participation in our contests, sweepstakes or promotional activities or request;
• To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
• For internal training and quality assurance purposes;
• To understand and assess the interests, wants, and changing needs of consumers, to improve our website, our current products and services, and/or developing new products and services; and

• To provide personalised products, communications and targeted advertising as well as product recommendations to you.

When we collect and use your personal data for purposes mentioned above and for other purposes, we will inform you before or at the time of collection.

Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

In some cases, we rely on legitimate uses for processing your personal data. A legitimate use could exist for example, when you sign up for a loyalty scheme with one of our brands and you voluntarily provide your personal data to extend the loyalty scheme and services, offers, etc. to you.

We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose, or we may be compelled to process personal data to report suspicious transactions under the local anti-money laundering rules.

 

Profiling

Unilever uses your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments. These segments are used by Unilever to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the Unilever brands on the Unilever sites, and via third-party websites. The segments can also be used for third-party campaigns on the Unilever sites. Unilever profiles your data where you have provided consent for us to do so; for example, signing up for marketing communications from Unilever brands or participate in a Unilever Survey.

You can withdraw your consent to prevent your personal data being used this way at any time by Contacting Us and opting out of the same.

By way of example –

• Unilever collects data, from:
  • Our websites about what you view and the way you interact with our content;  
  • Our digital display advertising that we serve to you on social platforms and other publisher’s websites; and  
  • Forms you fill in online and send to us about what your interests are.
• We also track the products you buy when you click on one of our display adverts and go on to purchase something from a selection of our retail partners.
• If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.
• We use this data to profile your likes and dislikes.  For instance, if we see that you are regularly viewing Vegan recipes on our “Recipedia” website, and you have opted in to receiving emails from us, we might give you an update on the new Vegan recipes that have just hit the site for your interest, or we may tailor our web content when you visit towards things, we think you’ll be most interested in.
• Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with.  Sometimes, with your consent, we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.
• We may also use information you have provided to selected third-parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising. 

As part of the Unilever Group, a global business, Hindustan Unilever Limited shares your personal data within the Unilever Group and with selected third-parties in the following circumstances:

• Third-party service providers. In order to carry out your requests, respond to your inquiries, fulfil your orders, honour coupons, provide you with samples, enable you to participate in sweepstakes or make various other features, services and materials available to you through our websites we share your personal data with third-party service providers that perform functions on our behalf, such as companies that: host or operate Unilever’s websites, process payments, analyse data, provide customer service, postal or delivery services, and sponsors or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.
• Other third-parties. Your personal data will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment (to find out more about our privacy key terms follow the link) and other offers, as well as product information. In the event, third parties are using the personal data beyond our purpose independently, they should obtain your valid consent or have legitimate use to process it for such purpose.
• Business transfers. Your personal data will be used by us or shared with the Unilever Group, primarily for business and operational purposes.  As Unilever Group continues to develop the business, it may sell or purchase assets, subsidiaries or business units.  In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to Unilever’s websites, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.  Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible they will be sold or transferred to third-parties.
• Legal disclosure. We may transfer and disclose your personal data to third-parties:
  • To comply with a legal obligation;
  • When we believe in good faith that an applicable law requires it;
  • At the request of governmental authorities conducting an investigation;
  • To verify or enforce our “Terms of Use” or other applicable policies;
  • To detect and protect against fraud, or any technical or security vulnerabilities;
  • To respond to an emergency; or otherwise
  • To protect the rights, property, safety, or security of third-parties, visitors to Unilever’s websites, Unilever or the public.

International data transfers

Due to the global nature of our operations, Unilever engages with Unilever Group companies or with third parties outside the country. Therefore, HUL may share personal data or processed data across international borders for purposes described in this Privacy Notice but will make sure that the personal data is protected in a similar manner. However, your data will only be transferred if permitted and in accordance with applicable local and international regulations.

Unilever takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.

Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible. We have also adopted processes, safeguards and measures to enhance protection personal data, your privacy and lawful processing of your data and your privacy.

Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.

We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you make a purchase online with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.

Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.

If we collect identifiable data directly for targeting purposes, we retain it till the purpose of targeting/marketing is relevant and of your interest. We will ensure that we do not engage in indiscriminate and/or excessive targeting or marketing to you. In the event you withdraw you consent or opt out to being targeted or marketed, we employ measures to permanently delete within reasonable time, unless required for other valid purposes under law.

We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

Where we process your personal data, you have several rights over how the data is processed and can exercise these rights at any point. You can exercise your rights by contacting us as provided under the Contact Us section. We have provided an overview of these rights below together with what this entails for you:

• The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Notice.

• The right to access, update and rectification: You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.

• The right to be erasure/forgotten: Under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.

• The right to object: Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).

• The right to withdraw consent: If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below. However, you would appreciate that withdrawal of consent to process necessary information may lead to us not being able to extend services, products, platforms or continue our business relationships.

• Rights to Nominate: You may nominate another individual to exercise control or rights to your personal data as and when prescribed under law, in the event of your death or incapacitation.

• The right to Grievance Redressal. You have the right to raise a request to exercise your Data Principal rights mentioned herein or under law or further raise grievance pertaining to your personal data with us as provided under the Contact Us section below.

·  The right to lodge a complaint with a Supervisory Authority: You have the right to lodge a complaint directly with any local Supervisory Authority as provided by and in accordance with applicable regulation.

Further information and advice about your rights can be obtained from the data protection Regulator in your Country.

We are committed to protect your personal information collected and processed by us and look forward to your continued support for the same. If you have any query, grievance with respect to the processing of information by us, you can reach out to us by calling our Toll Free No. 1800-10-22-221 or by email to lever.care@unilever.com or submitting a request through the “Contact Us (Privacy Request/Concern)” form available on the HUL website.

You can also reach out to our Privacy Office in the event of any escalation or absence of resolution of grievance, requests, rights pertaining to personal data processed by us. You may contact our DPO/Privacy Grievance Officer at (1) The Data Protection Officer/Privacy Grievance Officer, Hindustan Unilever Limited, Unilever House, B. D. Sawant Marg, Chakala, Andheri (E), Mumbai - 400 099 or at: Grievance.Officer-Privacy@unilever.com. You can also call on the aforementioned contact number and request it to be referred to the DPO/Data Protection Office.

When a privacy question or access request is received, we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. If you are unsatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

We will update this Privacy Notice when necessary to reflect customer feedback, our practices, scope of processing, and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the bottom of this Notice. You are encouraged to periodically visit this page to review the Privacy Notice and any changes to it. Your continued use or access after any modification(s) to this Privacy Notice, will be deemed as your acceptance to such modification(s). If the changes are significant or sensitive, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes).

Additional Privacy Terms or Notices

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.