As you would be providing the personal data of individuals associated with you (such as employees, contractors, agents, partners, consultants, personnel, etc.) for a commercial/business engagement with us, you shall ensure that such data is accurate and updated. You are also responsible for compliance with applicable laws, including personal data regulations and should inform the individuals sufficiently about the processing, including this Privacy Notice and obtain their agreement, prior to sharing such information on their behalf.
BUSINESS CUSTOMER, BUSINESS PARTNER, VENDOR AND SUPPLIER PRIVACY NOTICE
YOUR PRIVACY IS IMPORTANT TO US!! Please read the following Privacy Notice to learn about how Hindustan Unilever Limited (HUL) collects and processes the personal data/information of individuals associated with organizations working and partnering with us. This Privacy notice will not only inform you of the personal we collect, but also the purpose for which it is collected, your corresponding rights with respect to the same.
BACKGROUND
Hindustan Unilever Limited (“HUL” or “Unilever” or “We” or “Us”) has always been at the forefront to support and work collaboratively with our distributive trade/customers (retailers, wholesalers, sales partners, etc.), vendors, suppliers, and business partners towards administrative and operational efficiency to improve our and their products/services, and effectively compete in the market.
In furtherance of the same, while working with us, organizations, and individuals such as your employees, contractors, personnel, etc. associated with them, are required to share information, including personal. When we use personal data, we do so with integrity and transparency, upholding the rights of the individual in accordance with our values and the law. This helps us to build and maintain trust, which enables us to create meaningful, closer, and long-lasting relationships, with our customers, partners, and suppliers.
1. Personal Data means any information that can be used to identify directly or indirectly a specific individual. For e.g. Name, Mobile Number, Address, Financial Information (Bank Details, etc.), Biometric Data (Facial images, finger print), Health data, Digital Identifiers, etc. We always limit the circumstances where we collect and process these special categories of data. We will collect these directly from you and in a transparent manner.
2. We may collect personal data from a variety of sources. This includes:
• Personal data you or your organization give us directly when you or organization is onboarded or engaging with us or is using our services, platforms, etc.
• Personal data we collect automatically (We also receive and store certain types of personal data whenever you interact with us online through your devices. For example, we use cookies and tracking technologies).
• Personal data we collect from other sources such as partners, third parties for background verification, credit worthiness, business decision making, business communications, etc.
3. The following types of personal data may be processed by HUL:
a. Name of the Organization and details thereof such as address, legal documentations (GST, PAN, FSSAI License, Trade License, Ownership details, etc.).
b. Identifiers such as name, gender, contact details such as mobile number, Organization you are associated along with designation, responsibilities, authority, etc.
c. Financial Information of the Organization or individuals associated with organizations for financial transactions, payments, credit worthiness, etc.
d. Transaction Data of the Organization and/or individuals on account of the organization such as order history, payment information, credit, etc.
e. Geo-Location data of the individual operating our Platforms, Portals to track product/service deliveries, attendance, operational efficiencies.
f. Facial images and/or biometrics for identification verification, attendance, etc.
g. Government issued identifications such as PAN, Driving License, Aadhar, etc.
h. Business and Individual Performance for operational excellence, incentives, payouts, etc.
i. Screening and Background Verification Information.
j. Information regarding suspected or actual criminal or unlawful behaviour, records, proceedings, etc.
k. Information on trainings, qualifications, etc.
l. Information processed during inquiry, grievance handling, surveys, etc.
m. Cookies and other similar tracking technology to improve business and operational efficiencies or communications. You can read our Cookie Notice for greater detail.
n. Health data or information in the event medical facilities or benefits are extended as part of our commercial relationship to individuals of the Organizations associated with us.
o. Equity, Diversity and Inclusion related information and status of the Organization, its ownership or workforce, which may result in processing of individual’s related personal data.
1. The purpose of the processing of information is on account of a commercial and business relationship between HUL and your organization or you and our intent is to process business relevant information and data. However, due to the nature of engagement even in commercial relationships, Personal Data of individuals associated with us for commercial/business purpose is required to be processed for the same. Therefore, all the purposes of processing Personal Data under this Privacy Notice are towards business/commercial engagement, operations and efficiency.
2. We would be processing Personal Data for the following purposes:
a. Assessment and screening of potential organizations to partner/work with us.
b. Onboarding the organization or you as a customer, vendor, business partner, etc. As part of the same, details of the individuals’ associated with the organization are also provided.
c. Background verification, credit worthiness, credibility of the organizations and individuals associated with the organization.
d. Managing relationships with Organizations and individuals we work with.
e. Business execution such as transacting with you, providing our products/services, making payments, etc.
f. Use of our platforms/portals for managing business/commercial transactions such as procurement, order processing, invoicing, payments, etc.
g. To build operational efficiencies and administration for our partner Organization and HUL, we also use or provide platforms/services to manage their personnel, employees, etc. to drive better business execution and performance. For e.g. Partner organizations may use our Platforms to manage HR Lifecycle, services, amenities, facilities facilitated by us, for their employees, personnels, etc. associated with them.
h. For research, profiling your business/business transactions, and analysis to improve our products, services, and operations.
i. We strive for Equity, Diversity, and Inclusion (ED&I) and encourage our partner organizations to drive the same. Therefore, we conduct surveys to identify partner organizations ED&I status or promoting the same, run programs to extend support, incentivize, etc. to encourage the same. Organizations in some instances share minority, diversity, disability information of ownership, workforce, etc. to validate the same. We however ensure that such information is handled with utmost sensitivity for this limited purpose and limit collecting the same wherever possible.
j. To protect against security incidents, attacks, fraud, illegal activities, non-compliance with laws etc.
k. We may use such data to send communications on updates, offers, services, beneficial facilities, or Programs relevant and available for our Partner organizations.
l. Run Customer/Business Partner Reward Programs, etc.
3. Where appropriate, we will ask for your further explicit 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. However, it is possible that on withdrawal of consent, we may be unable to offer services and use of our platform to you as a result.
The personal data provided by you shall be shared or disclosed for processing for the purposes explained above and only where necessary and need to know basis.
1. Third Parties: HUL works with various third parties, including but not limited to authorized partners, service providers, auditors, contractors, data processors, etc. who help extend support and services towards our business operations. Your data may be shared with relevant third parties for processing in the event they are supporting or providing services for the purposes described in this Privacy Notice.
2. Sharing of Data with Unilever Group of Companies: Due to the global nature of our operations, your data would be shared with our parent company “Unilever Plc” and other affiliates, subsidiaries, companies associated with our parent company forming part of the Unilever Group (Unilever Group Companies) for global operational efficiency (central storage/processing, use of global platforms/portals/services, etc.), security, commercial/business relationship with other Unilever Group Companies, etc. Your Personal data shared shall always be used in accordance with this Privacy Notice and adequately protected irrespective of jurisdiction of the same.
3. Business Transfers: 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.
4. 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.
• For any other legitimate use provided under applicable laws.
11. 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.
12. HUL takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorized 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, pseudonymize and anonymize 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, including when processed by third parties.
13. We will keep your personal data for as long as we need it for the purpose it is being processed for. Your data being processed arising out our business relationship is retained for period of the business relationship and certain limited purpose thereafter. We retain your data with us to address any queries, grievances, disputes pertaining to the business and contractual relationship, financial settlement, etc. Further, HUL may be required to retain business transaction or relationship data, including relevant personal data for legal, regulatory, statutory compliance, tax, financial reporting etc.
14. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a statutory, legal, or business need for it to be retained.
1. 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 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.
• 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.
16. 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.
17. 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.
18. This Privacy Notice is subject to modification based on business, legal or regulatory requirements and will be updated online. We will make all efforts to communicate any significant changes to this Privacy Notice, to you. You are encouraged to periodically visit this page to review the Privacy Notice and any changes to it. Your continued use of the App after any modification(s) to this Privacy Notice, will be deemed as your acceptance to such modification(s).
Last Updated: 5 March 2024