Equilibra S.r.l., a company of the Unilever group in Italy, with registered office at: via Plava 74, Turin (TO), adheres to the policy on the processing of personal data of users in the digital spaces of companies in the Group, as set out below. Therefore, this Privacy Policy also applies to the digital spaces managed by Equilibra S.r.l.
We know that you care about your personal data and the means in which it is used, and we want you to have confidence in it being processed on behalf of Unilever. This privacy notice will help you to understand what data we collect, why we collect it and how we process it.
This information applies to Unilever Italia Mkt. Operations S.r.l. and Italian companies in the Unilever Group.
Please take a moment to familiarise yourself with our Cookie Notice and if you have any queries, please contact us by email at: privacy@equilibra.it or send a request via the “Contact us” form on our Website.
We have tried to keep this notice as simple as possible, but if you are not familiar with terms such as ‘cookie’, ‘IP address’ and ‘browser’, please read these key terms before proceeding.
You have the right to object to certain processing of your personal data, including the use of personal data for direct marketing purposes. Find out what your rights are and how you can exercise them here.
WHO COLLECTS INFORMATION?
All personal data provided or collected by Unilever is processed by the Italian Unilever Group company that owns the site, the Data Controller.
Details of the websites and the company that is the Data Controller are set out below
*Websites created by Equilibra for specific initiatives, such as competitions (which will be discontinued once the initiative has ended) or sites with a communicative function but that are not designed for direct sales are not included in the list above.
This Privacy Policy applies to personal data collected by Unilever in relation to the services and products that we offer. In this text, references to “Unilever” indicate the Italian companies in the Unilever Group that act as Data Controller.
This Privacy Policy also applies to Unilever marketing content, including offers and advertisements for Unilever products and services, which we (or a service provider that acts on our behalf) send to you on third-party Websites, platforms and applications based on information on the use of your site. These third-party Websites generally have their own privacy policy and terms and conditions. We invite you to read them before using those Websites.
For e-commerce spaces on the websites www.equilibra.it and www.dettofranoi.it, the Unilever companies that own the sites (Equilibra S.r.l. and Unilever Italia Mkt. Operations S.r.l. respectively) - as better specified in the specific privacy policy available on the registration page in the reserved area - they act as Joint Data Controllers for the following purposes: management of users, direct marketing, postal marketing, profiling of navigation data (as better described in the Cookie Policy) and profiling of purchases.
Users who register in the reserved area of the website www.equilibra.it or the website www.dettofranoi.it may use the same credentials to access the reserved area of both websites. The same credentials may also be used to register for competitions organised by Equilibra S.r.l. and Unilever Italia Mkt. Operations S.r.l.
Click here for more details.
WHAT PERSONAL DATA IS COLLECTED?
Personal data means all information that may be used to identify a specific person, directly or indirectly.
Unilever does not require you to provide 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 respond to any queries you may have with a high-quality service.
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;
and personal data that we collect from other sources.
Personal data means all information that may be used to identify a specific person, directly or indirectly. This definition includes personal data collected offline through our Consumer Engagement Centres, direct marketing campaigns, sweepstakes 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 this personal data with other companies that are part of the Unilever Group, in accordance with this Privacy Policy. We may also combine this data with other information to improve our products, services, content and advertisements.
Unilever does not require you to provide 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 respond to any queries you may have with a high-quality service.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect personal data from a variety of sources. These include:
Personal data that you provide us with directly. We collect data on how you use our services and products, for example the type of content that you view or interact with, or the frequency and duration of your activity. We collect the personal data that you provide to us when you sign up for a marketing newsletter, when you fill in a survey or register an account to purchase our products. When this occurs, we might request personal data such as your name, gender, date of birth, address, email address, telephone number or credit card details. Some Unilever brands might collect “special categories of personal data” about you, with your specific consent. For further information about the special categories of data that we collect and how we use it, please refer to the relevant section below.
Personal data that we collect automatically. We receive and store some types of personal data every time that you interact with us online. For example, we use cookies and tracking technologies (see our privacy terms for more information) to obtain personal information when your browser accesses our Websites or advertisements and other content served by or on behalf of Unilever on other websites. Your personal information is also collected when you search, purchase, post, enter a contest or answer a questionnaire or communicate with our customer service teams. Examples of the types of personal data we collect include: IP address (see our privacy terms for more information), 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 joins with similar information of other consumers. While browsing the Unilever Website, we may also use software tools to measure and collect session information, including page response times, download errors, duration 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 to identify your device for the purposes of fraud prevention and diagnostics.
Personal data that 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+. We also receive information about you and the interactions of other visitors with our advertisements to measure whether our advertising is relevant and successful. We also collect information about you and your activities from third parties when we offer services or products jointly or from third-party data enhancement service providers (see our privacy terms for more information) who may provide insights to Unilever about the personal information we hold.
WHEN AND WHY WE COLLECT “SPECIAL CATEGORIES OF PERSONAL DATA”
Some categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classed as “special categories of data” and are covered by enhanced protection under European data protection legislation.
We limit the circumstances in which we collect and process these special categories of data.
Unilever occasionally collects data relating to your health such as allergies, pregnancy or information on skin type to send you personalised adverts and relevant promotions. Unilever collects and uses this personal data only if you have previously expressed your consent in this regard. In certain cases, you may have requested services or products that do not directly involve the collection of particular categories of data but might involve or suggest information regarding your religion, health or other special categories of data.
We have provided the following examples to illustrate the circumstances in which Unilever collects and processes special categories of data.
Unilever collects the due date of pregnant women on the page for signing up to the Zwitsal or Baby Dove newsletter; these are global pages. It can also place cookies on the registration page, which acquire this information. This data is used to create a demographic of mothers-to-be who receive online advertising from relevant Unilever brands. For further information about Unilever’s profiling activities, please see the relevant section.
Similarly, Unilever collects personal data relating to consumers’ allergies to provide them with advertising and promotions for products that are more relevant to their needs.
HOW DO WE SAFEGUARD CHILDREN’S DATA?
We understand the importance of taking extra precautions to protect the privacy and safety of children who use Unilever products and services.
Most Unilever Websites are designed for and intended to be used by adults. Where one of our Websites is intended for a younger audience, we gain the consent of the responsible person, primarily the parent, before collecting personal data, if this is required by law and by applicable legislation (the age at which consent is necessary varies from country to country).
If you are a minor who is under the age for which parental consent is required in your country, you should review the terms of this privacy policy with a parent or guardian to make sure that you have understood and to knowingly accept them. If we discover that we have collected the personal data of a minor without the consent of a parent or guardian where such consent should have been obtained, we will proceed to promptly erase such personal data.
Access to certain parts of Unilever Websites and/or eligibility to receive prizes, samples or other rewards is generally restricted to users of a certain age.
Sometimes we use your personal data to perform age verification checks and to be able to apply such age restrictions.
WHAT PURPOSES DO WE USE YOUR PERSONAL DATA FOR?
We collect, process and disclose your personal data solely for specific and restricted purposes. For example, to process your payments where necessary/required; assess and deal with any complaints; to develop and improve our products, services, means of communication and the functionality of our Website; and to provide personalised products, communications and targeted advertising; as well as product recommendations.
We also create profiles by analysing information about online browsing, search and purchasing 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 by using automated means. An automated decision is a decision that is made exclusively using automated means, which may occasionally involve the exclusion of human intervention or involvement in the decision-making process regarding the user’s personal data.
We collect, process and disclose your personal data only for the following purposes:
to process your payments if you purchase our products, to provide you with the status of your order, to handle your requests and questions, to assess and deal with any complaints;
to process and respond to your requests or contact you to respond to your questions and/or requests;
to develop and improve our products, services, means of communication and the functionality of our Websites;
for the purposes of competitions or promotions in which you have taken part;
to provide you with information and manage your registration and/or subscription to our newsletter or other communications;
to manage our daily business with regard to your participation in our competitions, contests for prizes or promotional activities or requests;
to authenticate the identity of people who contact us by telephone, electronic or other means;
for internal training and quality assurance purposes;
to understand and assess the interests, wishes and changing needs of consumers, improve our Website, our current products and services and/or develop new products and services;
and provide personalised products and communications and targeted advertising as well as product recommendations.
PROFILING
Unilever uses your personal data to create profiles. We also create profiles by analysing information about online browsing, search 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 customise advertisements on Italian Unilever websites, using users’ browsing data through the “lookalike” targeting system, according to which, if user A is similar to user B and user C, then it is likely that user A has similar interests and preferences to users B and C. These segments are used by Unilever to personalise the website and our communications with you (such as displaying content that is relevant to you when you visit our site, or in a newsletter) and display offers and adverts related to Unilever brands on the Unilever sites and via third-party websites. Segments can 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 cookie settings on your online browser or by registering to receive email newsletters from one of our brands.
In addition, if you are registered with one of our sites at the time of authentication, Unilever may associate your identifying data (such as your email address) with non-directly identifying browsing data that was previously collected through cookies during your visits to our sites and interactions with our content.
You can withdraw your consent at any time to prevent your personal data being used in this way by using the cookie management section of our cookie policy or by cancelling your email subscription 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 on what you view and how you interact with our content; our digital display advertising that we provide on social platforms and other websites of the publishers; registration forms for our websites; and forms you fill in online and send us about what your interests are.
We are informed about the products you purchase when you click on one of our display adverts and when you purchase something from a selection of our business partners.
If you have asked to receive email or SMS communications from Unilever, we keep track of whether you open, read or click on content to see what you are interested in, so that we can give you more of the content we think you will enjoy.
We use this 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 chosen to receive emails 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 customise our content towards things that we think will interest you most when you visit the site.
Based on this profile information, we may also show you advertisements that we think you may like and wish to see when you view our content or from our network of publishers who we advertise with. From time to time, with your consent, we may use your current location to send advertising messages relevant to promotions or events that are taking place nearby and which we think might interest you.
We might use the information that you have provided to selected third parties and agreed to being shared, such as age, gender, stage of life, lifestyle and broader interests to identify people who we think have similar interests to you and who we believe will be interested in similar advertisements.
For the profiling of data on purchases made on e-commerce platforms belonging to the Unilever Group, please see the appropriate notice available during registration with the reserved area.
AUTOMATED DECISION-MAKING PROCESSES
In certain cases, Unilever also processes your personal data using automated means. An automated decision is a decision that is made exclusively or predominantly using automated means, in which human intervention in the decision-making process regarding the user’s personal data is limited.
For example:
Unilever uses gamification for science-based behavioural evaluations and data science techniques to assess future employees. Candidates are required to play a series of games and the behavioural patterns exhibited during gameplay are assessed by a personalised Unilever algorithm 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 make decisions based exclusively on automated decision-making processes that may have a significant impact on you. If we do this, we inform you by providing you with clear information about our decision to rely on automated processing to make our decision and our legal basis for doing so. For example, Unilever processes your personal data with automated means only where this is necessary to execute a contract with you or when you have given your explicit consent.
You have the right not to be subject to a decision based exclusively on automated processing and which produces legal effects or other significant effects with respect to you. In particular, you have the right to:
obtain human intervention;
express your point of view;
obtain an explanation of the decision reached after an assessment and challenge that decision.
WHO WILL IT BE SHARED WITH?
As a company that is part of the Unilever Group – a global business – Unilever shares your personal data with the Unilever Group and with selected third parties in the following circumstances:
Third-party service providers. To fulfil your requests, respond to your enquiries, fulfil your orders, process coupons, provide you with samples, enable you to participate in sweepstakes, or make various other features, services and materials available through our Websites that we share your data with, third-party service providers who carry out 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 necessary to perform their duties but they cannot use it for other purposes. Also, they have to process this personal data in accordance with this privacy policy and as permitted by law and applicable regulations on data protection.
Other third parties. Your personal data will be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks and analyst firms or other third parties in relation to marketing, promotion, data enhancement (to find out more about our key privacy terms via the 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 mainly for commercial and operative purposes. As a group, Unilever continues to develop our business, we may sell or purchase goods, subsidiaries or business units. In such transactions, personal data is generally one of the company resources transferred, but it remains subject to promises made in any pre-existing privacy policy (unless, obviously, you do not give your consent). If another entity takes over us, our assets or all or part of our resources or the resources associated with the Unilever Websites, your personal data will be disclosed to those entities as part of the due diligence process and will be transferred to such entities as one of the assets transferred. In addition, if any bankruptcy or reorganisation proceedings are brought against us, all such personal data will be considered one of our assets and as such may 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, security or protection of third parties, visitors to Unilever Websites, Unilever or the public.
INTERNATIONAL DATA TRANSFER
Unilever shares personal data with the Unilever Group or with third parties for the purposes described in this privacy policy.
Unilever will only send personal data collected within the European Economic Area (EEA) overseas in circumstances such as:
following your instructions;
comply with a legal requirement;
or work with the agents and consultants we use to manage our business and services.
If we transfer personal data outside of the EEA, Unilever will ensure that it is protected in the same as if it had been processed in the EEA. We will take one of the following security measures:
Transfer to a non-EEA country whose privacy legislation guarantees an adequate level of protection of personal data comparable to that of the EEA;
Enter into a contract with the overseas third party, meaning they must protect personal data to the same standard as the EEA;
or Transfer personal data to organisations that are party to specific agreements on the cross-border transfer of data with the European Union (e.g. Privacy Shield, a framework that defines the standards of confidentiality 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 against misuse, interference, loss, unauthorised access, modification or disclosure.
Our measures include the implementation of appropriate access controls, investment in the latest information security features to protect the IT environments that we use and the guarantee of encryption, pseudonymisation and anonymisation of personal data where possible.
Access to your personal data is only permitted by our employees and agents on a need-to-know basis and is subject to strict contractual confidentiality obligations when processed by third parties.
HOW LONG DO WE STORE PERSONAL DATA?
We will store your personal data for as long as is necessary for the purposes for which it was processed. For example, when you make an online purchase with us, we will keep the data related to your purchase, so that we can execute the specific contract that you have entered into, and we will subsequently keep your personal data for a period that allows us to manage or respond to any complaints, questions or queries regarding the purchase.
Your data may also be stored so that we can continue to improve your experience with us and to ensure you receive any loyalty rewards you are due.
We store identification data that we collect directly for targeting purposes for the shortest time possible, after which we take measures to permanently erase it.
We will actively analyse the personal data in our possession and will erase it securely. In some cases, we will anonymise it unless otherwise required by law, the needs or interests of the company or those of the consumer to store it.
WHAT ARE YOUR RIGHTS?
Your rights in relation to your personal data and how it is processed. You can exercise these rights at any time. An overview of these rights together with what this entails for you is given below. You can exercise your rights by sending an email or request via the “Contact us” form on our Websites.
Where we process your personal data, you have a set of rights on how the data is processed and you can exercise these rights at any time. An overview of these rights together with what this entails for you is given below. You can exercise your rights by sending an email or 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. Therefore, we provide this 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 and if you wish to exercise your rights, please contact us.
The right to data portability. The personal data that you have provided may be subject to portability. This means that it can be moved, copied or sent electronically in certain circumstances.
The right to be forgotten. In certain circumstances, you have the right to request that we erase your data. If you wish for us to erase personal data that we hold about you, please notify us and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data that we collect is no longer necessary for any purpose and we are not obliged by law to store it, we will make every effort to erase it, destroy or de-identify it permanently.
The right to restrict processing. In certain circumstances, you have the right to request that we 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 (for example, receipt of notification emails from us or to be contacted with various potential opportunities).
The right to file a claim with a supervisory authority. You have the right to submit a claim directly to any local supervisory authority about how we process your data.
The right to withdraw your consent. If you have given your consent to everything that we do with your personal data (i.e. if we rely on your 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, this does not mean that everything that we have done with your personal data with your consent up until that time is illegal). You can withdraw your consent to the processing of your personal data at any time by contacting us using the details below.
Rights related to the decision-making process. You have the right not to be subject to a decision based exclusively on automated processing and which produces legal effects or other significant effects with respect to you. In particular, you have the right to:
- obtain human intervention;
- express your point of view;
- obtain an explanation of the decision reached after an assessment and challenge that decision.
Further information and advice about your rights can be requested from the data protection authority in your country.
HOW CAN YOU CONTACT UNILEVER?
For any question or query, information about Unilever’s privacy or the processing of data or if you wish to make a complaint about a possible infringement of local privacy laws, please do so by emailing: privacy@equilibra.it, or send a request via the “Contact us” form on our Website.
When a query about privacy or an access request is received, we have a dedicated team that processes contacts and responds to the specific concern or the request you are trying to raise. Where the issue might be more substantial in nature, you might be asked to provide further information. All these significant contacts receive a response. If you are not satisfied with the response received, you can direct your complaint to the supervisory authority in your country. If you request it, we will do everything possible to provide you with information about the relevant ways to complain that might be applicable to your circumstances.
HOW DO WE KEEP THIS NOTICE UP TO DATE?
We will update this Privacy Notice when necessary to reflect on the feedback of customers and the amendments to our products and services. When we publish amendments to this statement, we will adjust the “last updated” date at the top of this Notice. If the amendments are significant, we will provide a more prominent notice (including, for some services, notification via email of the amendments to this privacy policy). We will also store previous versions of this Privacy Policy on file for your reference.
We will not restrict your rights under this Privacy Notice without your consent.
FURTHER CONDITIONS OR NOTICES ABOUT PRIVACY
In addition to this Privacy Notice, there might be specific campaigns or promotions that are regulated by additional terms or privacy notifications. We invite you to read these additional terms or notifications before taking part in such campaigns or promotions, as you will be required to comply with them if you participate. Any additional terms or notifications about privacy will be made clearly available to you. Please also note that the collection of personal data on websites managed by the Data Controller – where necessary for individual features and objectives – will always be preceded by a specific notice prepared pursuant to applicable legislation.
