IMPACT PRIVACY NOTICE

Background

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 shipment tracking route optimized application – The Impact Application (“The App”) is an initiative towards the same and we thank you for being a part of our journey.
This Privacy Notice will ensure that you have a clear, unambiguous, and informed understanding of the use of any personal data that you or your employers share with us. Please read this Privacy Notice carefully before you consent to the terms and conditions in this Notice.
As part of the use of the App, we would be processing certain personal information of individuals on account of them being employees, contractors, agent, associate of any third party, service provider, or partner who uses the App as part of our distributive sales network.
In the event you are an employer/partner sharing personal data of your personnel for the use of this application directly, we request you to inform them of the same, including this Notice and the purpose of the same, before you process the same under this Application.
By using on the App and providing the details, you or any third party who you are associated with, represents 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 Data Collected:

Personal Data means any information that can be used to identify, directly or indirectly, a specific individual. For e.g. Name, Mobile Number, Address, etc.
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.

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

Name of Distributor and Unique Distributor ID.
Name of Retailer and Unique Retailer ID.
Delivery team’s name and mobile number.
Vehicle Name and Phone numbers provided by the distributor.
OTP Verified Mobile number registered by HUL.
Business Name and Pin code of the Retailer.
Any data that is provided by you to HUL, or our Distributor, as part of the commercial relationship.
Latitude-Longitude details for retail outlets.
Live Location tracking for delivery optimization.

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

Purpose

The primary purpose of this application is not to process personal data specifically but for commercial/business purpose for helping increase logistics efficiency for our distribution network and partners. Therefore, the purpose of the application is to process business/commercial related information. However, as you would appreciate, certain personal information may be shared by you or your employer for this limited purpose.
HUL will collect, process, and share your personal data for the purpose of allowing you to track the delivery and route status of your shipment, on its way to the end consumers (“Purpose”). All personal data shall be processed in accordance with the Privacy Notice of the App, and HUL shall always protect such personal data and your trust.
We collect, process, and disclose your personal data only for specific and limited purposes, including but not limited to, providing services on this Application, to assess and handle any complaints, to develop and improve our products, and services.
The App may access, collect, analyse your usage of the App and other information related to your location on a regular basis through Bluetooth and Wi-Fi signals, and other technologies and data for the performance of the services provided by the App, and to help improve the design, functionality, performance, and content of the App . In order to collect the geo-location information, location settings must be enabled on your Device. Therefore, in some cases, the App may request that you enable the location settings.
Except in cases where any specific services requested by you, require or involve personal identification, the App collects location data anonymously and in a form that does not personally identify you. By using the App, you agree and consent to transmission, collection, maintenance, processing and use of your location data and queries to provide and improve such services of the App.
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.
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, you or the third party organization you are associated with may not be able to use our App to function as part of our distributive network.

Sharing of data with third parties

In order to provide the services associated with the App, HUL will collect, process, use, transfer and retain relevant data, including personal data of registered subscribers to this the Application. This data may be shared with third party, within different Unilever Group Companies and other vendors/service providers for the purpose of provision of services on The App.
Business Transfers: Your personal data will be used by us or shared with the Unilever Group, primarily for business and operational purposes. As Unilever Group continues to develop the business, it may sell or purchase assets, subsidiaries, or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to Unilever’s websites, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible, they will be sold or transferred to third-parties.
Legal disclosure: We may transfer and disclose your personal data to third parties:

To comply with a legal obligation;
When we believe in good faith that the Applicable law requires it;
At the request of governmental authorities conducting an investigation;
To verify or enforce our “Terms of Use” or other the 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.

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 the Applicable data protection norms and established information security standards.

Protecting your Data

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.
Our measures include implementing the 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.
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

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.

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 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 data portability : The personal data you have provided us with may be portable. This means it can be moved, copied, or transmitted electronically under certain circumstances.
The right to be erause/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 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.
The right to lodge a complaint with a Supervisory Authority : You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your personal data, subject to local regulations.

Retention of Data

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.
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.
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.
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.

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

Updation of Notice

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: 26-Sep-2023 ^[a]