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PRIVACY NOTICE


#YOURDATAISYOURS

We know that you care about your personal data and how it is used, and we want
you to trust that Unilever uses your personal data carefully. This Privacy
Notice will help you understand what personal data we collect, why we collect it
and what we do with it.

As you read our Notice, please keep in mind that it applies to Unilever South
Africa Proprietary Limited and any company directly or indirectly owned, or
controlling, or controlled by, or under common control with Unilever, joint
ventures and franchises, that you may be interacting with or have a business
relationship with (“Unilever”).

Please take a moment to familiarise yourself with our privacy practices and let
us know if you have any questions by sending us
an email at UnileverSA.privacy@unilever.co.za or submitting a request through
the “Contact Us” form on our websites.

We have tried to keep this Notice as simple as possible, but if you’re not
familiar with terms, such as cookies, IP addresses, and browsers, then please
read about these key terms first.


You have the right to object to certain uses of your personal data including the
use of your personal data for direct marketing. See what your rights are and how
you can exercise them here.


WHO IS COLLECTING IT?

Any personal data provided to or collected by Unilever is controlled by Unilever
South Africa Proprietary Limited, the data controller.

This Privacy Notice applies to personal data collected by Unilever in connection
with the services and products we offer.

This Privacy Notice also applies to Unilever’s marketing content, including
offers and advertisements for Unilever products and services, which we (or a
service provider acting on our behalf) send to you on third-party websites,
platforms and applications based on your site usage information. These
third-party websites generally have their own Privacy Notice and Terms and
Conditions. We encourage you to read them before using those websites.


WHAT PERSONAL DATA IS BEING COLLECTED?

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

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 our products
or services, or with a high quality of service or respond to any queries you may
have.

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. 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 South Africa Proprietary Limited companies may share your personal
data with 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. 

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 our products
or services, or with a high quality of service or respond to any 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, 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.

 * 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.

 * 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 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 personal information” and
benefit from additional protection under the South African data protection
legislation.

We limit the circumstances where we collect and process these special personal
information.  

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 collects and uses 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
personal information, but may imply or suggest your religion, health or other
special personal information.

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

 * Unilever collects personal data related to consumers’ allergies to provide
   consumers with ads and promotions for products which are relevant to their
   needs.

 


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 the person with parental responsibility before we collect personal
data where it is required by applicable laws and regulations (the age at which
consent is necessary varies from Country to Country). 

If you are a child under the age where parental consent is required in
your Country, you should review the terms of this Privacy Notice with
your parent or guardian 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 guardian where such consent should have been obtained, we
will delete that personal data as soon as practical. Access to certain parts of
the 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.


WHAT PURPOSE DO WE USE YOUR DATA FOR?

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 and use your personal data 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 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.

We process your personal data to perform a 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.

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.

 


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; 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 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 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.  For instance, if we see
   that you are regularly viewing Vegan recipes on our “Recipedia” website, and
   you have opted in to receiving emails from us, we might give you an update on
   the new Vegan recipes that have just hit the site for your interest, or we
   may tailor our web content when you visit towards things we think you’ll be
   most interested in.
 * 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.
 * 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.

 


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. 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.

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.

You have the right not to be subject to a decision which is based solely on
automated processing and which produces legal or other significant effects on
you. In particular, you have the right:

 * to obtain human intervention; 

 * to express your point of view;

 * to obtain an explanation of the decision reached after an assessment; and

 * to challenge such a decision.


WHO WILL IT BE SHARED WITH?

As part of the Unilever Group, a global business, Unilever South Africa
Proprietary 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 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. 
 * 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; 
   * 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.   

Unilever will only send personal data collected within a restricted legal
framework, such as e.g. the European Economic Area (EEA) or Asian Pacific
Economic Cooperation (APEC), to countries which do not have data protection laws
that are considered to provide appropriate levels of protection in the
restricted legal framework in circumstances such as:  

 * To follow your instructions;  

 * To comply with a legal duty; or  

 * To work with our agents and advisers who we use to help run our
   business and services.  

If we do transfer personal data to outside of the restricted legal framework,
Unilever will make sure that it is protected in the same way as if it was being
used in that restricted legal framework. We’ll use one of the following
safeguards:  

 * Transfer to another Country whose privacy legislation ensures an adequate
   level of protection of personal data similar or equivalent to the country it
   was collected in;  

Put in place a contract with the third-party that means they must protect
personal data to the same standards as in the country the data was collected
in. 


HOW DO WE PROTECT YOUR PERSONAL DATA?

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
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.


HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

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 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.

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. 


WHAT ARE YOUR RIGHTS?

Your rights in relation to your personal data how it is processed. You 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
sending an email to unileversa.privacy@unilever.com or submitting a request
through the “Contact Us” form on our websites.

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 sending an email to unilever.privacysa@unilever.com
or submitting a request through the “Contact Us” form on our websites.

 * 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 restrict processing. Under certain circumstances, you have the
   right to restrict the processing of your personal data.
 * 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 lodge a complaint with a Supervisory Authority. You have the
   right to lodge a complaint directly with the Information Regulator at
   POPIAComplaints@inforegulator.org.za  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., 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.
 * Rights related to automated decision-making. You have the right not to be
   subject to a decision which is based solely on automated processing and which
   produces legal or other significant effects on you. In particular, you have
   the right:
   * to obtain human intervention; 
   *  to express your point of view;
   * to obtain an explanation of the decision reached after an assessment; and
   *  to challenge such a decision.

 Further information and advice about your rights can be obtained from the
Information Regulator:

Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg

 Email: enquiries@justice.gov.za

Website: http://www.justice.gov.za/inforeg/index.html


HOW DO YOU CONTACT UNILEVER?

Unilever nominated an Information Officer who can be contact at Unilever 15
Nollsworth Crescent, Nollsworth Park, La Lucia Ridge Office Estate, La Lucia,
4051, or by email at UnileverSA.privacy@unilever.co.za.

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 at UnileverSA.privacy@unilever.co.za or submitting a request through
the “Contact Us” form on our websites. 


HOW DO WE KEEP THIS NOTICE UP TO DATE?

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.


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 Nov 2021


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