Privacy Policy

#yourdataisyours

We know you care about your personal data and the way they are used, and we want you to trust Unilever in processing them. This privacy policy will help you understand what personal data we collect, why we collect them and how we process them.

The information contained herein applies to Unilever Italia Mkt. Operations S.r.l. and the Italian companies in the Unilever Group.

Please take a moment to familiarize with our Cookie Notice and contact us if you have any questions sending us an email or submitting a request via the “Contact Us” form on our websites.

We tried to keep this notice as simple as possible, but if you are not familiar with terms such as “cookies”, IP addresses and browsers, please read these key terms before proceeding.

You have the right to object to certain processing of your personal data, including the use of your personal data for direct marketing purposes. Find out what rights you have and how you can exercise them here.

 

Who gathers the data?

All personal data provided or collected by Unilever are processed by the Italian company in the Unilever Group that owns the site, in its capacity as the Data Controller.

The following is a detail of the websites and the company in charge of the processing:

WebsiteUnilever Group Companies
www.equilibra.itEquilibra S.r.l. with registered office at Via Plava no. 74, Turin (TO)
www.dettofranoi.itUnilever Italia Mkt. Operations. S.r.l. with registered office at via Paolo di Dono no. 3/A, Rome

*The above list does not include websites created by Unilever for specific initiatives, such as contests (which will cease to exist when the initiative ends) or informational websites that are not designed for direct sales.

This Privacy Policy applies to personal data collected by Unilever in connection with the services and products we offer. In this text, references to “Unilever” indicate the Italian companies in the Unilever Group, which act as Data Controllers.

This Privacy Policy also applies to Unilever’s marketing content, including offers and advertisements for Unilever products and services, that we (or a service provider acting on our behalf) send you on third-party websites, platforms and applications based on information about your use of the website. These third-party websites generally have their own privacy policies and terms and conditions. We recommend that you read them before using those websites.

For e-commerce spaces on Unilever websites, the Unilever companies that own the websites (Equilibra S.r.l. and Unilever Italia Mkt. Operations S.r.l., respectively) – as specified in the privacy policy available on the registration page of the reserved area – act as Joint Data Controllers for the following purposes: account management, direct marketing, postal marketing, profiling of browsing data (as better described in the Cookie Policy) and profiling of purchases.

The user subscribing to the reserved area of this website can use the same login credentials to access the reserved area of the websites indicated in the table above. The same access credentials can also be used to register for contests organised by Equilibra S.r.l. and Unilever Italia Mkt. Operations S.r.l.

For further details click here. To view the extract of the Joint Ownership Agreement click here.

 

What personal data is collected?

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

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

We may collect personal data from a variety of sources. These include:

  • personal data that you provide to us directly
  • personal data that we collect automatically
  • personal data that we collect from other sources.

Personal data is any information that can be used to directly or indirectly identify a specific person. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, lotteries and contests; and online, through our websites, applications and brand 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 may share these personal data with other Unilever Group Companies consistently with this Privacy Policy. We may combine these data with other information to improve our products, services, content and advertising.

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

 

How we collect your personal data

We may collect personal data from a variety of sources. These include:

Personal data that you provide to us directly. We collect data about your use of our services and products, such as the types of content that you view or interact with, or the frequency and duration of your browsing. We also collect personal data that you provide when you sign up for a marketing newsletter, complete a survey or register an account to purchase our products. When this happens, we may ask for personal data such as your name, gender, date of birth, address, e-mail address, phone number or credit card details. Some Unilever brands may collect “special categories of personal data” about you with your specific consent. For more information about the special categories of data we collect and how we use them, please refer to the relevant section below.

Personal data we collect automatically

We receive and retain certain types of personal data whenever you interact with us online. For example, we use cookies and tracking technologies (to find out more, please see our privacy key terms) to obtain personal data when your browser accesses our websites or advertisements and other content served by or on behalf of Unilever on other websites or advertisements and other content served by or on behalf of Unilever on other websites. Your personal data are also collected when you search, purchase, post, enter a contest or questionnaire, or interact with our customer service teams.

Examples on the types of personal data we collect include: IP address (for more information, please see our privacy key terms), device ID, location data, computer and connection data 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 data from other consumers. As you browse the internet on Unilever websites, we may also use software tools to measure and collect session data, including page response times, download errors, length of visits to certain pages, page interaction data, and methods used to browse away from the page. We may also collect technical data 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 from our trusted partners and where we manage Unilever accounts on third party platforms, for example, when you use the “Like” feature on Facebook or the +1 feature on Google+. Furthermore, we receive data 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 third parties when we jointly offer services or products or from third party data enrichment service providers (to learn more see our privacy key terms) who may provide insights to Unilever about the personal data we hold about you.

 

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

Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and enjoy
enhanced protection under EU data protection legislation.
We limit the circumstances in which we collect and process these special categories of data.

Unilever sometimes collects data about your health such as allergies, pregnancy status or skin type to send you tailored ads and
relevant promotions. Unilever collects and uses these personal data only with your prior consent. In some cases, you may have requested services or products that do not directly involve the collection of specific categories of data, but may involve or suggest data relating to your religion, health or other special categories of data.

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

Unilever collects pregnancy due dates of mothers-to-be on the Zwitsal or Baby Dove newsletter sign-up page, which are global web pages. Unilever may also place cookies on the registration page, which gather these data. These data are then used to create an audience of mothers-to-be, who receive online advertising from relevant Unilever brands. For more information on Unilever’s profiling activities, please see the relevant Clause.

Similarly, Unilever collects personal data about consumers’ allergies to provide consumers with advertisements and promotions for products that are best suited to their needs.

 

How do we protect children’s privacy?

We understand the importance to adopt further precautions to protect the privacy and safety of children who use Unilever products and services.

Most of Unilever websites are designed and intended for adults. Where one of our websites is intended for a younger audience, we will obtain the consent from the person in charge, the parent in the first instance, before collecting personal data if this is required by applicable laws and regulations (the age at which consent is required varies from country to country).

If you are a child under the age for which parental consent is required in your country, you should review the terms of this Privacy Policy with your parent or guardian to make sure you understand them and to knowingly agree. If we discover that we have collected personal data from a child without the consent of a parent or guardian where such consent should have been obtained, we shall promptly delete those personal data.
Access to certain parts of the Unilever websites and/or eligibility to receive prizes, samples or other rewards are generally restricted to users of a certain age.
We sometimes use your personal data to conduct age verification checks and be able to enforce those age limits.

 

For what purpose do we use your personal data?

We collect, process and disclose your personal data only for specific and limited purposes, for example, to process your payments where necessary /
requested, evaluate and handle any complaints, develop and improve our products, services, methods of communication and functionality of our websites, and to provide customized products, targeted communications and advertising, and product recommendations.
We also create profiles by analysing data about online browsing, search and purchase behaviour, and interactions with our brand communications by creating segments (creating groups with certain common characteristics) and entering personal data into one or more segments.

Unilever also processes your personal data using automated means. An automated decision is one that is made solely by automated means, sometimes without human intervention or human involvement in the decision-making process regarding your personal data.

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

  • to process your payments, if you purchase our products, provide you with the status of your order, handle your requests and questions, evaluate and manage any reports to process and respond to your inquiries or contact you to answer to your questions and/or respond to your requests
  • to develop and improve our products, services, methods of communication and the functionality of our websites;for the purpose of contests or promotions in which you participated
  • to provide information and manage your registration and/or subscription to our newsletter or other communications
  • to manage our day-to-day business with respect to your participation in our contests, lotteries or promotional activities or requests
  • to verify the identity of persons who contact us by telephone, electronic means or otherwise; for internal training and quality assurance purposes
  • to understand and assess the interests, desires and changing needs of consumers, improve our website, current products and services and/or develop new products and services
  • to provide personalised products and communications as well as targeted advertising and product recommendations.

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

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

In some cases, we rely on a legitimate interest to process your personal data. A legitimate interest may exist, for example, when you sign up for a loyalty program with one of our brands and we use the personal data collected to conduct data analysis to improve our products or services. This data will only be used where necessary to achieve a legitimate interest, for example to assist in the performance of an agreement or optimise a service, and only where this does not interfere with your rights as an individual. This legal basis will only be invoked when there is no less intrusive way to process your personal data.

We can assure you that if the legitimate interest is used as a reason for processing your personal data, we will keep a record of this and you will have the right to request this information.
We process your personal data in the performance of an agreement to which you are or will be a party. For example, we need to process your personal data to deliver a product or service that you have purchased, to enable you to enter one of our contests or to send you samples that you have requested.

We also process your personal data to comply with legal obligations (e.g. tax or social security obligations) that must be complied with to carry out that processing. For example, a court order or writ of summons may require us to process personal data for a specific purpose or we may be required to process data to report suspicious transactions under local anti-money laundering regulations.

 

Profiling

Unilever uses your personal data to create profiles. We create profiles by analysing data about online browsing, searching, and interactions with our brand communications by creating segments (creating groups with certain common characteristics) and entering personal data into one or more segments. This processing is carried out in order to personalise online advertising on Unilever’s Italian websites, using users’ browsing data through the “Lookalike” system, according to which if user A is similar to user B and user C, then user A is likely to have similar interests and preferences to users B and C.

These segments are used by Unilever to personalize the website and our communications to you (such as displaying content that pertains to you when you visit our site or in a newsletter) and to display relevant Unilever brand offers and ads on Unilever sites and through third-party websites. Segments may also be used for third-party campaigns on Unilever websites. Unilever identifies your data where you have given us consent to do so; for example, by accepting the cookie setting on your online browser or by registering to receive e-mail newsletters from one of our brands.

Furthermore, if you have registered to one of our websites, Unilever may associate your personally identifiable data (such as your e-mail address) with non-personally identifiable browsing data previously collected through cookies during your visits to our websites and interactions with our content when you authenticate.

You may withdraw your consent at any time to prevent your personal data being used for the above purposes through the cookie management section of our Cookie Policy or by unsubscribing your e-mail if you have logged into one of our websites or subscribed to any marketing newsletters.

For example:

    Unilever collects data with your consent from: our websites about what you view and how you interact with our content; our digital display advertising on social platforms and other publisher websites; registration forms on our websites; and forms you fill out and send online on your specific interests.

We are informed about the products you purchase when you click on one of our display ads and when you purchase something from a selection of our business partners.
If you have requested to receive e-mail or SMS communications from Unilever, we track whether you open, read or click on content to see what you are interested in, so that we can give you more of that content that we think you will enjoy.

We use these data to profile your Likes and Dislikes. For example, if we see that you regularly view Vegan recipes on our “Recipedia” website and you have opted to receive e-mails from us, we may give you an update on new Vegan recipes that have just been added to the site for your interest, or we may tailor our content towards things that we think will interest you most when you visit the site.

Based on this profile data, we may also show you advertisements that we think you like and would like to see while viewing our content or content from our network of publishers with whom we advertise. At times, with your consent, we may use your current location to advertise messages about promotions or events occurring nearby that we believe may be of interest to you.

We may also use data that you have provided to selected third parties and consented to be shared, such as age, gender, stages of life, lifestyle and broader interests to identify people who we think have similar interests to yours and who we believe will be interested in similar advertising.

For the profiling of purchase data made in the e-commerce areas of the Unilever group, please refer to the specific data provided during registration in the reserved area.

Automated decision making

In some cases, Unilever also processes your personal data using automated means. An automated decision is a decision that is made exclusively or predominantly by automated means, where human intervention in the decision-making process concerning your personal data is limited. For example:

    Unilever uses game simulations of science-based behavioural assessments and data science techniques to evaluate prospective employees. Candidates are required to play a series of games and the behavioural patterns showed during gameplay are evaluated by a custom algorithm from Unilever to predict the candidate’s potential for a specific role. This algorithm is tested regularly to ensure that it remains fair, effective and unbiased.

We will not make decisions based solely on automated decision-making that may have a significant impact on you. If we do, we clearly inform you of our choice to rely on automated processing to make our decision and our legal basis for doing so. For example, Unilever processes your personal data by automated means only if it is necessary to enter into or perform an agreement with you or when you have given your explicit consent.

You have the right not to be subject to a decision based solely on automated processing and that produces legal or other effects that are significant to you. More specifically, you have the right to:

  • require human intervention
  • express your point of view
  • obtain an explanation on the decision reached after an evaluation, and challenge that decision.

 

Who will personal data be shared with?

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

Third Party Service Providers

To meet your demands, respond to your inquiries, fulfill your orders, apply vouchers, provide you with samples, enable you to participate in lotteries, or make various other features, services and materials available through our websites with which we share your data, we use third party service providers that perform functions on our behalf, such as companies that: host or operate Unilever websites, process payments, analyse data, provide customer support, postal or delivery services, and sponsors or other third parties who participate in or administer our promotions. They have access to the personal data they need to perform their functions but may not use it for any other purposes. Furthermore, they must process these personal data in accordance with this Privacy Policy and as permitted by applicable data protection laws and regulations.

Other third parties

Your personal data will be used by us or shared with our sponsors, advertisers, ad networks, ad servers, social media networks and analysis companies or other third parties in connection with marketing, promotion, data enrichment (to learn more about our privacy key terms follow this link) and other offers, as well as product information.
Commercial Transfers. Your personal data will be used by us or shared with the Unilever Group, primarily for commercial and operational purposes. As the Unilever Group continues to develop our business, we may sell or buy assets, subsidiaries or business units. In those transactions, personal data are generally one of the transferred business assets, subject however to the promises made in any pre-existing Privacy Policy (unless, of course, you agree otherwise). If another entity acquires us, our assets or substantially all or part of our assets or of the assets associated with the Unilever Websites, your personal data will be disclosed to that entity as part of the due diligence process and will be transferred to that entity as one of the transferred assets. Furthermore, if any bankruptcy or reorganization proceedings are commenced against us, all those personal data will be considered our asset and as such it is possible that they 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 government authorities conducting an investigation
  • to verify or implement our “Terms of Use” or other applicable policies
  • to detect and protect against fraud, or other 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 websites, Unilever, or the public.

 

International data transfers

Unilever shares personal data with the Unilever Group or third parties for the purposes described under this Privacy Policy.

Unilever will only send personal data collected within
the European Economic Area (EEA) to foreign countries in circumstances such as:

  • following your instructions
  • complying with a legal obligation
  • working with the agents and consultants we use to manage our business and services.

If we transfer personal data outside the EEA, Unilever will ensure that
they are protected in the same way as if they were processed within the EEA. We will take one of the following security measures:

  • Transferring data to a non-EEA country, the privacy legislation of which ensures a level of protection of personal data that would be appropriate in the EEA
  • Entering into an agreement with the foreign third party, i.e., they must protect personal data according to the same standards as in the EEA
  • Transferring personal data to organizations that are part of specific agreements on cross-border data transfers with the European Union (e.g., Privacy Shield, a framework setting privacy standards for data sent between the United States and European countries, or similar documents).

 

How do we protect personal data?

Unilever takes the security of your personal data very seriously. We make 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 data security features to protect the IT environments we use and ensuring
to encrypt, pseudonymise and anonymise personal data wherever possible.

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

 

How long do we keep personal data?

We will keep your personal data for as long as is necessary for the purpose for which they were processed. For example, when you make an online purchase from us, we will keep the data relating to your purchase in order to perform the specific agreement that you have entered into and then keep the personal data for a period allowing us to handle or respond to any reports, questions or concerns regarding your purchase.

Your data may also be kept in order to continue to improve your experience with us and to ensure that you receive the loyalty rewards you are owed.

We keep the identifying data we collect directly for targeting purposes for as short a time as possible, after which we employ measures to delete them permanently.

We will actively review the personal data we hold and securely delete them. In some cases we will anonymise them in the absence of other legal obligation, business or consumer need or interest to keep them.

 

What are your rights?

Your rights in relation to your personal data and how they are processed. You may exercise these rights at any time. Here is an overview of your rights and the consequence of such rights for you. You can exercise your rights by sending an e-mail or a request via the “Contact Us” form on our websites.

If we process your personal data, you are entitled to a number of rights over how the data is processed and you can exercise them at any time. An overview of these rights follows along with what this means for you. You can exercise your rights by sending an e-mail or a request via the “Contact Us” form on our websites.

The right to be informed. You have the right to receive clear, transparent and easily understandable information about how we use your personal data and about your
rights, which is what we are providing in this notice.

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

The right to data portability. The personal data you have provided to us may be subject to portability. This means that they can be moved, copied or transmitted electronically under certain circumstances.

The right to be forgotten. In certain circumstances, you have the right to request that we delete your data. If you wish to delete the personal data we possess 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 are no longer needed for any purpose and we are not legally obliged to keep them, we will endeavour to delete, destroy or de-identify them permanently.
The right to restrict processing. Under certain circumstances, you have the right to restrict the processing of your data.

The right to object. In certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (e.g., receiving e-mails from us informing you or being contacted with different potential opportunities).

The right to lodge a complaint with a supervisory authority. You have the right to complain directly to any local supervisory authority about how we process your personal data.

The right to withdraw consent. If you have given your consent to everything we do with your personal data (i.e., if we rely on your consent as the legal basis for processing your personal data), you have the right to withdraw your consent at any time (although, if you do this, it does not mean that everything 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.

Rights relating to automated decision-making. You have the right not to be subject to a decision that is based solely on automated processing and that produces legal or other significant effects for you. More specifically, you have the right to:

  • obtain human intervention;
  • express your point of view;
  • obtain an explanation on the decision reached after an evaluation; and challenge that decision.

Further information and advice on your rights can be obtained from the data protection officer in your country.

 

How to contact Unilever?

Unilever has appointed a Chief Privacy Officer who can be contacted at Unilever N.V., Weena 455, PO Box 760 3000 DK Rotterdam Netherlands or by e-mail.

If you have any questions or concerns about Unilever privacy or data processing practices, or if you would like to lodge a report about a possible b of local privacy laws, please do so by sending an e-mail or submitting a request via the “Contact Us” form on our websites.

When a privacy question or access request is received, a dedicated team will processes the contacts and address the specific concern or request you are trying to raise. Where the problem may be more substantial in nature, more data may be required from you. All of these substantive contacts receive a response. If you are not satisfied with the response you received, you can address your complaint to the relevant supervisory authority in your country. If you ask us, we will do everything possible to provide you with information about relevant avenues that may apply to your circumstances.

 

How do we keep this policy up to date?

We will update this Privacy Policy when necessary to reflect customer feedback and changes in our products and services. When we publish changes to this notice, we will change the “last updated” date at the top of this Notice. If the changes are significant, the changes will be easier to be noticed (for certain services, we may send e-mail notification of changes to the Privacy Policy). We will also keep previous versions of this Privacy Policy on file for your reference.

We will not reduce your rights under this Privacy Policy without your consent.

 

Additional terms or Privacy notices

In addition to this Privacy Policy, specific campaigns or promotions will be governed by additional terms or privacy notices. We encourage you to read these additional terms or notices before participating in any such campaign or promotion, as you will be required to comply with them should you participate. Any additional terms or privacy notices will be made available to you in a prominent manner. We would also like to inform you that the collection of personal data on the websites managed by the Data Controller – where necessary for single functions and purposes – will always be preceded by a specific privacy policy drawn up in accordance with the applicable legislation.

 

Last updated October 2020