SHIKHAR PRIVACY NOTICE

 

BACKGROUND

  1. Hindustan Unilever Limited (“HUL” or “Unilever” or “We” or “Us”) has always been at the forefront to digitize and support distributive trade partners to effectively compete in the market. Our B2B website and mobile application platform known as “Shikhar” (hereinafter referred to as “Platform”) is an initiative towards the same and we thank you for being part of our journey.

 

  1. This Platform is our initiative to enable the distributive trade to place orders for products from our distributors and avail various services as made available by HUL or its partners from time to time, to facilitate and strengthen your business.

 

  1. This privacy notice will ensure that you have a clear, unambiguous and informed understanding of the use of any personal data that you may consent to share with us. Please read this notice carefully before you consent to the terms and conditions in this notice.

 

  1. By entering/ registering on the Platform and providing the details, you represent that you are 18 years of age or older, and have understood the processing of your data in accordance with this Privacy Notice.

 

TYPE OF PERSONAL DATA COLLECTED

  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, Digital Identifiers, etc.

 

  1. Certain categories of Personal data, such as financial data, government id, health data, biometric data, etc. are considered as “special categories of data” by us and benefit from additional protection. 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.

 

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

 

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

 

The following types of personal data and sensitive personal data, including but not limited to may be processed by HUL:

 

  1. As stated above, the Platform and the services therein are for businesses and our intention is to collect business specific information and data. However, due the nature of the Platform, we are conscious that you may share certain Personal Data and may require further protection.

 

  1. Some other instances where your data might be collected by Unilever:

(A) 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 doing so, 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.

(B) 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 or advertisements and other content served by or on behalf of Unilever on other websites. 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 (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.

(C) 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 Privacy Key Terms | Unilever Legal (unilevernotices.com)) who may deliver insights to Unilever about the personal data we hold.

  1. 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. For example: Unilever uses game simulations of science-based behavioural assessments and data science techniques to assess prospective employees. Candidates are required to play a set of games and the behavioural patterns exhibited during gameplay are assessed by a Unilever customised algorithm to predict the candidate’s potential for a specific role. This algorithm is regularly tested to ensure it remains fair, effective, and unbiased. Your rights related to the same, subject to local regulations are described in the “Your Rights” section of this Notice. We will not make decisions based solely on automated decision making that have significant impact on you. If we do so we notify you and provide you with clear information about our decision to rely on automated processing to make our decision and our lawful basis for doing so. For example, Unilever processes your personal data using automated means only if it is necessary for the entering into or the performance of a contract with you, or when you have given your explicit consent.

 

PURPOSE

  1. HUL will collect, process and share personal data of individuals associated with your organization and transactional data as part of this Platform for the purpose of fulfilling our services under the Platform and also to provide and recommend ancillary services benefiting your commercial activity provided by HUL, affiliated and/or Unilever group companies, third party service providers or partners organisations. All personal data shall be processed in accordance with the Privacy Notice of the Platform and HUL shall always protect such personal data and your trust.

 

  1. We collect, process and disclose your personal data only for specific and limited purposes, for providing services under  this  Platform, process your payments, to assess and handle any complaints, to develop and improve our products, services, to offer promotions or opportunities to participate in competitions, to manage everyday usage and business need of our applications and platforms, communication methods and the functionality of our  Platform , to provide personalised products, communications and targeted advertising as well as product recommendations to you. This will also include processing your personal data to perform the obligations of the terms and conditions of this  Platform and any contract to which you are or will be a party. For example, we need to process your personal data to deliver a product or a service you bought, to allow you to take part in one of our competitions, or to send you samples that you have requested.
  2. We may 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.

 

  1. 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.

 

  1. In some cases, we rely on legitimate interest 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 assist in the performance of a contract, or to optimise a service, and does not outweigh your rights as an individual. This legal basis will only be relied upon where there is no less intrusive way to process your personal data. 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.

 

  1. 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.

 

  1. 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.

 

  1. Profiling:

(A) Unilever may use 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, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.

By way of example –

Unilever collects data, with your consent, from:

o Our websites and mobile applications about what you view and the way you interact with our content;

o Our digital display advertising that we serve to you on social platforms and other publisher’s websites; and

o Forms you fill in online and send to us about what your interests are.

(C) 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.

(D) We track whether you open, read or click on the content and communications sent by us to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.

(E) We may use this data to profile your likes and dislikes. 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.

(F) 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.

 

SHARING OF DATA WITH THIRD PARTIES:

  1. In order to provide the services associated with the Platform, HUL will collect, process, use, transfer and retain relevant data, including personal data of registered subscribers to this application. This data may be shared with third party, within different Unilever Group Companies and other vendors/service providers for purposes of provision of services on Platform , offering promotions and schemes from partners, offering credit facilities and payment facilities, and other services and offers.

 

  1. Your personal data may be shared with 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. Your personal data may 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 and other offers, as well as product information.

 

  1. 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.

 

  1. Further, the Software may provide the Company with information about your transaction, use of the Platform, and use of Content, Digital Content, other content, and the Services (such as search queries, installed applications, viewing and usage data, available memory, log files, network diagnostics, voice information, and connectivity). Information provided to the Company may be processed in the cloud to improve the User experience and the Services and may be stored on servers outside the country in which you live. We will handle any information we receive in accordance with the Privacy Policies.

 

  1. Legal disclosure: We may transfer and disclose your personal data to third-parties:
  1. 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. This information will be shared in compliance with applicable data protection norms and established information security standards.

 

International Data Transfer

  1. Unilever shares personal data within the Unilever Group or with third-parties for purposes described in this Privacy Notice, and may share personal data or processed data across international borders. However, your data will only be transferred if permitted and in accordance with applicable local and international regulations.

 

 

SHARING OF DATA BY UNILEVER GROUP COMPANIES:

  1. Other affiliates, subsidiaries, companies associated with our parent company “Unilever Plc.” forming part of the Unilever Group (Unilever Group Companies) are in cognate business and may also enter or explore ancillary services and/or similar B2B Platforms relevant to your commercial activity. HUL may share this data with its affiliates and/or Unilever group companies for the above stated purpose. Your personal data and non-personal data may be shared with such Unilever or HUL group company for them to assess your eligibility, value of such services, platforms, etc. and to reach out to your organization for your interest in availing or being onboarded for services, platforms by them.

 

PROTECTING YOUR DATA

  1. HUL 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.

 

  1. 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.

 

  1. 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.

 

YOUR RIGHTS PERTAINING TO PERSONAL DATA

  1. 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. You can exercise your rights by contacting our grievance officer.

 

RENTENTION OF DATA

  1. HUL will keep your personal data for as long as we need it for the purpose that 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.

 

  1. 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.

 

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

 

  1. HUL 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.

 

CONTACT US: FOR QUERIES, GRIEVANCES AND DATA PRINCIPAL RIGHTS

  1. We would be happy to address any queries pertaining to your data. As a first step you can reach out to our Shikhar team through: (1) Phone: XXXXXXXXXXXX (2) Email: XXXXXXXXXXXXXXXXX (3) WhatsApp: XXXXXXXXXXXX.

 

  1. HUL has also nominated a Data Privacy Officer (DPO) or Privacy Grievance Officer. If you have any query about our Privacy Notice, personal data or grievance which the team is unable to resolve, you may contact the DPO/Privacy Grievance Officer at Hindustan Unilever Limited, Unilever House, B. D. Sawant Marg, Chakala, Andheri (E), Mumbai - 400 099 by addressing the DPO or also through email at: Grievance.Officer-Privacy@unilever.com.

 

  1. You can also 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” form available on the HUL website.

 

  1. 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. All such substantive contacts receive a response. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

 

UPDATION OF NOTICE

  1. 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.

 

ADDITIONAL PRIVACY NOTICES OR TERMS

  1. In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices, including that of third parties such as payment gateway providers, collaboration partners, etc. We encourage you to read these additional terms or notices, where made available.

Last Updated: 20th September,2023