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/natural person. 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. Unilever Sri Lanka Limited may share your personal data with 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 certain products or services, or with a high quality of service or respond to some 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, sex, date of birth, address, email address, telephone number or credit card details. Some Unilever brands may collect “special categories of personal data” about you. For more information on the special categories of personal 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 find out more, see our privacy key terms) to obtain personal data when your web browser accesses our websites. Your personal data is also collected when you search or, buy our products/services or, 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 (to find out more see our privacy key terms), 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 process “special categories of personal data”

Certain categories of personal data, such as race, ethnicity, religion, health, sexual orientation, genetic data or biometric data are classified as “special categories of personal data” (to find out more see our privacy key terms) and benefit from additional protection under the law.

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

For instance, 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 processes 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 personal data, but may imply or suggest your religion, health or other special categories of personal data.

We will only process special categories of personal data where we are able to satisfy an additional condition for doing so. Accordingly, we may use one of the following additional conditions for processing special categories of personal data, where consent is not the appropriate basis for the same.

·      the processing is necessary to respond to an emergency that threatens the life, health or safety of you or another natural person,

·      the processing relates to personal data which is manifestly made public by you,

·      the processing is necessary for the establishment, exercise or defense of legal claims, or

·      the processing is otherwise expressly permitted under relevant laws or regulations of Sri Lanka

How do we protect children’s privacy?

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 a parent or a person who has the parental authority or who has been appointed as legal guardian before we collect personal data relating to a child below the age of eighteen (18) years as it is required by applicable laws and regulations in Sri Lanka. (the age at which consent is necessary varies from country to country).

If you are a child under the age where consent of a parent or a person who has parental authority over you or who has been appointed as your legal guardian is required in your country, you should review the terms of this Privacy Notice with one of such persons 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 a person who has parental authority or who has been appointed as legal guardian where such consent should have been obtained, we will delete that personal data as soon as practical. Access to certain parts of 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 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 your personal data from you for purposes mentioned above or 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 interest (of ours or of a third party) for processing your personal data. A legitimate interest could exist for example, when you sign up for a loyalty scheme with one of our brands and we use the personal data collected to conduct data analytics to improve our products or services. This ground will only be used where it is necessary to achieve a legitimate interest, for example to optimise a service, and does not outweigh your rights as an individual. We can assure you that if legitimate interest is used as a ground for processing your personal data, we will keep a record of this and you have the right to ask for this information.

We process your personal data to perform a contract to which you are a party or to take steps at your request prior to entering into a contract with you. For example, we need to process your personal data to deliver a product or a service you bought..

We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing as per Sri Lanka law. For example, a court order or a summons 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.

In some instances, we may have to process your personal data to respond to an emergency the threatens the life, health or safety of you or another person.

We also process your personal data where it is necessary for the performance of a task carried out in the public interest.

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 by opting in; for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.

You can withdraw your consent to prevent your personal data being used this way at any time using the manage cookies section of our Cookie Notice or unsubscribing to the use of your email address if you have logged into one of our websites or signed up to any marketing newsletters.

By way of example –

Unilever collects personal data, with your consent, 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 or otherwise 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. 

Based on this profile information, we may also give you advertising (if you have asked us to do so) 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, sex, 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.

Automated decision-making

In some instances, Unilever processes your personal data 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 will not generally make decisions based solely on automated decision. If we do so we notify you and provide you with clear information about our decision to rely on solely automated processing to make our decision and our lawful basis for doing so.

You have the right to request us to review a decision made based solely on automated processing which has created or which is likely to create an irreversible and continuous impact on your rights and freedoms guaranteed under any written Sri Lanka law.

However, the aforesaid right to request us to review a decision made, based solely on automated processing, does not exist if automated processing is necessary for the entering into or the performance of a contract with you, or when you have given your consent, or if authorized by any written law of Sri Lanka which we are subject to, or where the Data Protection Authority of Sri Lanka has authorised such processing.

As part of the Unilever Group, a global business, Unilever Sri Lanka 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 should not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice, subject to appropriate safeguards and only as permitted by the Personal Data Protection Act No. 9 of 2022 of Sri Lanka, as may be amended or replaced (the “PDPA”).

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.

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 as per Sri Lanka law;

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

Unilever shares personal data within the Unilever Group or with third-parties for purposes described in this Privacy Notice.

Further, Unilever may send your personal data out of Sri Lanka to any country prescribed by the Data Protection Authority of Sri Lanka pursuant to an adequacy decision, or if it is to a country not so prescribed, only when we are satisfied that, (i) regardless of transfer of your personal data to such country, we are able to comply with our mandatory obligations under the PDPA, and (ii) only after executing an appropriate instrument as prescribed by the Data Protection Authority of Sri Lanka, with the recipient of data in such country or as otherwise permitted by the PDPA.

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 appropriate Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise personal data wherever possible.

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, concerns, actions or suits relating to the purchase.

Your personal 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.

We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.

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 a number of rights over how the data is processed and can exercise these rights at any point. 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, rectification and completion. You have the right to access, correct or complete your personal data at any time.
• The right to erasure. Under certain circumstances, you have the 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 restrict processing. Under certain limited circumstances, you have the right to restrict the processing of your personal data, such as where we are required to maintain your personal data for evidentiary purposes under Sri Lanka law or on an order of a competent court without rectifying, despite your request for rectification.
• The right to object. Under certain circumstances, you have the right to object to further processing of personal data.
• The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with the Data Protection Authority of Sri Lanka about how we process your personal data.
• The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e., where 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.
• Rights related to automated decision-making. Under certain circumstances you have the right to request for a review of a decision made by us which is based solely on automated processing which has created or which is likely to create an irreversible and continuous impact on your rights and freedoms.
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• How can you exercise your rights?
• You can exercise your rights by sending a request by email to consumercare.usl@unilever.com  or submitting a request through the “Contact Us” form on our websites.
• In the event you make a request in relation to your rights, we will respond to you within twenty-one (21) working days and inform you whether your request has been granted, refused (with reasons therefor) or whether we have refrained from further processing your personal data.
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• In certain instances, we would request specific information from you to help us confirm your identity and to ensure that you have the right to exercise any such rights.
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• When a request is received and where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. We may refuse your request based on certain grounds to the extent permitted by applicable law.
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• If you are unsatisfied with the reply received, you may refer your complaint to the Data Protection Authority of Sri Lanka.
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• We may refuse your request based on certain grounds to the extent permitted by applicable law.
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• We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the Personal Data you may request.

Viraj Ferdinandes, Data Protection Officer of Unilever can be contacted by email at dataprivacy.advisorSL@unilever.com

If you have any questions or concerns about Unilever’s Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an email (consumercare.usl@unilever.com ) or through these channels (Call – 1323 (Toll Free) and/or SMS/ WhatsApp – 077 700 2 700) or by submitting a request through the “Contact Us” form on our websites.

We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.

We will not reduce your rights under this Privacy Notice without your consent, unless otherwise permitted in law.

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.

Last updated February 2025