PRIVACY POLICY
PRIVACY PRINCIPLES
Unilever takes your privacy seriously. The following principles guide our treatment of your personal information:
- We value the trust you place in Unilever when sharing your personal information with us.
- We strive to be transparent with you about what information we collect, what we do with it and with whom we share it.
- We will work with you to promptly address your concerns about how we use your personal information.
- We will take steps to keep your personal information secure and to protect it from misuse.
UNILEVER PRIVACY POLICY – YOUR PRIVACY RIGHTS
Effective Date: [To be inserted upon finalization]
SCOPE
This Privacy Policy (“Policy”) describes how UL MarketDirect, which is owned by Conopco, Inc. d/b/a Unilever (“Unilever”, “we”, or “us”) treats personal information on our websites, portals, and mobile applications where the Policy is located, including the mobile versions of our websites (collectively, the “Portal”). The Portal is intended for business and enterprise customers only, and UL MarketDirect only intends to collect information about users in their capacity as employees or representatives of our business and enterprise customers.
1. TYPES OF INFORMATION WE COLLECT
UL MarketDirect collects information from you and about you. Here are some examples of the information we may collect:
- Contact Information. For example, we may collect your name, mailing address, phone number and email address. If you create an account, we may also collect your vendor number.
- Purchase and Preference Information. We may collect information that relates to your product preferences and shopping behavior, such as your order history and which products and categories of products you have browsed.
- Payment Information. For example, if we enter into a sales transaction with you, we (or the service provider we engage to process payments) may collect your credit card number and billing address, or other payment info. Note that if you make a purchase from a third-party supplier on the Portal, that sales transaction will be between you and the seller, and UL MarketDirect will not receive any payment information in relation to that transaction.
- Internet and Network Activity Information: We may collect your IP address when you visit our Portal. We also use tracking tools like cookies and pixels to automatically collect information about how you interact with our Portal and online content. This might include device identifiers, the type of browser and operating system you are using, your browsing and search history on the Portal, what areas of the Portal you visit and for how long, what products or content you view and click on, what site you came from to get to us and what site you go to when you leave us, and your interactions with our digital ads and content on other sites. If you use our app, we might look at how often you use the app and where you downloaded it.
- Information You Post to the Portal. We may collect information you post in a public space on our Portal, such as product reviews.
- Social Media Information. We may collect information you post on our social media pages. We may also collect your social media profile information and information posted on your page.
- Information You Submit to us. We may collect information when you send us a message through the email address on the Portal or the livechat feature on the Portal, or if you call our support number. We may also collect information when you enter a promotion. This may include photos, videos and other user-generated content that you submit.
- Location Information. For example, we may collect precise location information from your device. This may include information about your exact location when you use our Portal or mobile application. For more information about your options related to the collection of your location information, see the Choices section below.
2. HOW WE USE YOUR INFORMATION
Examples of how we may use your information include:
- To Provide Our Portal, Products, and Services. We may use your information to operate and provide the Portal and to make available our products and services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions, assisting distributors or other sellers in completing transactions with you, or managing your shopping list.
- To Improve Our Portal, Products, and Services.We may use your information to make our Portal, products and services better. We may also use your information to customize your experience with us.
- To Understand Your Interests. For example, we may use your information to better understand what products interest you.
- To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
- To Communicate With You. We may communicate with you about your account, our relationship, your orders, or any questions or comments you have submitted. We may also contact you about this Policy or our Terms of Use
- To Determine Your Eligibility or Verify Your Credit History. We may use your information to verify your identity and credit history, or to determine your eligibility for some of our products, services and promotions. For example, this may include verifying your location, email address, phone and/or name.
- For Marketing Purposes. We may provide you with information about new products and special offers. We might use your information to serve you ads about products and offers. We might tell you about new features or updates. These might be for UL MarketPlace, for other Unilever brands, or for third party offers or products we think you might find interesting. We may also use your information to send you electronic communications, including through email or text message. We and our partners may engage in interest-based advertising using information gathered across multiple websites, devices, or other platforms. For more information about your choices related to these communications, see the Choices section below.
- To Protect the Portal, Our Users, and Others. We use information to protect Unilever (including our Portal), our users, and third party suppliers and other sellers who use the Portal. We may also need to use your personal information to investigate and remediate fraud or other suspected illegal activity.
- To Send Push Notifications.If you use our mobile apps, we may send you push notifications about new products or special offers.
- For verification purposes. For example, we will use certain pieces of information to verify your identity if you make requests pursuant to this Policy. The verification steps and the pieces of information that we request may vary depending on the sensitivity and nature of your request.
- As Otherwise Permitted By Law or As We May Notify You.
3. HOW WE COLLECT YOUR INFORMATION
UL MarketDirect collects your information in different ways. Below are some examples of how we may collect your information.
Directly From You. For example, when you:
- Register for an account.
- Purchase products through the Portal.
- Sign up to receive our emails.
- Join a loyalty, rewards or similar program or club.
- Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.
- Submit a product review.
- Submit a request or inquiry to our service team.
- Interact with Unilever social media pages.
Automatically From Your Devices. For example, we use tracking tools to automatically collect information from your device when you:
- Install and use Unilever mobile apps.
- Visit and navigate our Portal on any device.
- Enable location-based features on our Portal.
- Click on sponsored links or third-party advertisements.
- We may also collect information about users over time and across different websites, apps and devices when you use the Portal. Third parties also collect personal information this way on our Portal.
From Vendors That Provide Services To Us. We may get information about you from our vendors that provide services to us, including, for example, vendors we engage to host or maintain the Portal, process payments, distribute orders, send emails, provide marketing, advertising, or adtech services, or provide us with analytics and research.
From Our Parent And Affiliate Companies.We may get information from other Unilever Group companies and brands.
From Other Third Parties. We may receive information about you from other sources. For example, this may include receiving information from:
- Our business partners, including distributors and other sellers on the Portal, store owners, online advertising networks, and companies that co-sponsor our promotions.
- Social media sites.
- Companies that provide information to supplement what we already know about you, including data aggregators.
By Combining Information. For example, we may:
- Combine information that we collect offline with information we collect through our Portal.
- Combine information we collect about you from the different devices you use to access our Portal.
- Combine information we get from third parties with information we already have about you.
4. WITH WHOM WE MIGHT SHARE YOUR INFORMATION
UL MarketDirect may share your information in the following ways:
- With Our Parent and Affiliate Companies. We may share your information within the Unilever Group of companies and brands.
- To Users On our Portal. For example, we may display information you post on our product reviews pages.
- With Vendors Who Provide Services To Us. We may share your information with vendors who perform services on our behalf. For example, this may include vendors we engage to host or maintain the Portal, process payments, distribute orders, send emails, provide marketing, advertising, or advertising technology services, or provide us with analytics and research.
- With Our Business Partners. For example, we may share information with distributors and other sellers on the Portal. We may also share information with data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers.
- With Third Parties for Their Own Marketing Purposes. This may include third parties in whose products or services we believe you may be interested. These third parties may use your information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising. These third parties may also share your information with others.
- With Any Successors to All or Part of Our Business. For example, if Unilever merges with, acquires or is acquired, or sells a part of its business to another business entity, we may share your information as part of the diligence process and/or as part of the actual transaction. This may include an asset sale, corporate reorganization or other change of control.
- To Comply With the Law or To Protect Ourselves. For example, we may share your information when responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might share information when we are investigating a potential fraud. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
- For Other Reasons We May Describe to You.
5. COOKIES & OTHER TRACKING TECHNOLOGIES
We automatically collect certain types of usage and device information when you visit our Portal, read our emails, or otherwise engage with us. We typically collect this information through cookies (a small text file sent from a website and stored on your device), web beacons, pixels, and similar tracking technologies. We may utilize third party services to collect this information. For example, these tracking technologies may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID, and about the way you engage with our Portal, for example, the site from which you came and the site to which you are going when you leave our Portal, the pages you visit, how frequently you access our Portal, whether you open emails or click the links contained in emails, whether you access the Portal from multiple devices, the products you view and click on, and similar actions you take.
We use this information collected through tracking technologies to provide custom, personalized content and information (including targeted content and advertising), to recognize you across multiple devices, to monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and to otherwise enhance our Portal and your user experience.
Interest-Based Advertising:
We and third-party advertising networks, social media companies, and other services may collect information about your use of our Portal over time and across different devices so that they or we may display advertising that is more likely to be relevant to you and your interests. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
6. YOUR CHOICES REGARDING YOUR INFORMATION
You have certain choices about how we use your information.
Marketing Communications:
You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account, orders, and responses to your inquiries. To opt out of receiving our marketing communications, you can email us at info@ulmarketdirect.com or follow the “unsubscribe” instructions in any marketing communication we send you.
You Can Control Cookies and Tracking Tools:
Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. If you block cookies, certain features on our Portal may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use. To control flash cookies, which we may use on certain sites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
Our Do Not Track Policy:
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Mobile Application and Location Based Services:
- If you have previously opted into Unilever collection and use of location-based information through our mobile applications, you may opt-out by adjusting the settings on your mobile device.
- You may completely opt-out of all location-based information collection by Unilever if you uninstall all Unilever mobile apps from your devices.
7. YOUR CALIFORNIA PRIVACY RIGHTS
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at info@ulmarketdirect.com or write to us at the address listed below. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
If you are a California resident, you can also make the following requests with respect to your personal information, pursuant to the California Consumer Privacy Act (“CCPA”):
- Access – You can request that we disclose to you the following: (i) the categories of personal information that we have collected about you; (ii) the categories of sources from which we have collected personal information about you; (iii) the business or commercial purpose for collecting or selling your personal information; (iv) the categories of personal information that we have sold about you and the categories of outside parties to whom the personal information was sold; (v) the categories of personal information that we have disclosed about you for our business purposes and the categories of vendors to whom the personal information was disclosed; and (vi) the specific pieces of personal information that we have collected about you over the past 12 months.
- Deletion – You can request that we delete the personal information that we maintain about you, subject to certain exceptions.
- Do Not Sell My Personal Information – You can request that we not sell your personal information by clicking Do Not Sell My Personal Information. For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable California law. Certain companies may place tracking technologies on the Portal, and those companies receive information about your activity on the Portal that is associated with your browser or device. This may be considered a “sale” under California law. To opt out of cookie-based tracking for advertising purposes, you should visit our AdChoices page here. Your selections are specific to the device and browser you are using, so you should make these selections on each device and for each browser you use to access the Portal. Please note that those selections are deleted whenever you clear your browser’s cache.
We will not discriminate against you because you exercised any of these rights. Please note that the above rights related to access and deletion do not apply to certain personal information collected in the business-to-business (B2B) context.
Please submit a request by filling out our California Resident Rights Request Form or by emailing us at info@ulmarketdirect.com . We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Note that the above rights to access and deletion may not apply to employees and other representatives of businesses who are interacting with Unilever in their professional capacity.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
We want our California residents to know the following specific disclosures about how we handle personal information:
- We collect and use the following categories of personal information as set forth in the CCPA: Identifiers; Payment and customer records information; Commercial information; Internet or other electronic network activity information; and Geolocation data. We collect this Personal Information from the sources described above.
- We collect and use the above categories of personal information for the business and commercial purposes described in Section 2 of this Policy.
- We collect these categories of personal information from the sources described in Section 3 of this Policy.
- We may disclose each of the foregoing categories of personal information for the business and commercial purposes described in this Privacy Policy to the extent permitted by applicable law to the categories of third parties as described in Section 4 of this Policy.
- We may “sell” categories of personal information, including: Identifiers (such as IP address); Commercial information; Internet or other electronic network activity; and geolocation data. We may “sell” these categories of personal information to the categories of third parties described in Section 4 of this Policy.
8. SECURITY
The Internet is not 100% secure. We cannot promise that your use of our Portal will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to help safeguard personal information under our control. A username and a password are needed to access certain areas of the UL MarketDirect Portal. It is your responsibility to protect your username and password.
9. UNITED STATES ONLY
The Portal is intended only for users in the United States, and products will only be shipped to United States postal addresses. If you access the Portal from outside of the United States, you understand that we may transfer your personal information to the United States, and you consent to such transfers. Please be advised that your use of the Portal is governed by United States law. The data protection laws of the United States may not provide the same level of protections as those in your own country. Information we maintain may be stored by us or our vendors in and outside of the United States.
10. MINORS UNDER 18 YEARS OF AGE
The Portal is a B2B marketplace and does not knowingly sell products for purchase by minors under the age of 18. Our Portal is intended for adults who are primarily purchasing for a business. If you are a parent or legal guardian and believe your child under 18 has provided us with personal information, please email us at info@ulmarketdirect.com .
11. LINKS
Our Portal may contain links to external sites that are not governed by this Policy. If you click on a link to a third party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third party sites.
12. HOW TO CONTACT US
If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to email us atinfo@ulmarketdirect.com .
13. CHANGES TO POLICY
From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Portal. Please check our Portal periodically for updates.