Effective Date: January 1, 2020
JUUL Labs holds our customer base in the highest regard and is dedicated to providing the best experience on our Services. In order to offer an enjoyable and premium experience on our Websites, we collect information which can personally identify you (e.g., name, address and email) and information that is about you but that does not identify you individually (e.g., aggregate information on the number and frequency of visits to various pages of the Websites). The categories of information we collect can include:
A. Information that you provide to us
We may collect personal information that you provide to us directly, such as your name, phone number, location, payment information, and e-mail address when you when you register on our Websites, purchase a product, sign up for our Newsletter mailing list, or otherwise communicate with us (e.g., via customer service). Account creation is required when purchasing products from the Websites. We may also collect any communications between you and JUUL Labs and any other information you provide to JUUL Labs. If you download and use our mobile App to access the Service, the App does not require you to enter any personally identifiable information, though you may voluntarily provide information to us through the App, for example, when you contact us through the App’s customer service link and provide to us your name, email address and any information you choose to include in the text of your message.
We use this information to operate, maintain, and provide to you the features and functionality of the Websites, as well as to communicate directly with you, such as to send you email messages. We may also send you service-related emails or messages (e.g., account verification, change or updates to features of the Websites, technical and security notices).
B. Information automatically collected
The App may store information regarding usage of a compatible JUUL Labs device that you have linked to the App when the App is running or when a compatible JUUL Labs product is available to pair with the App. Such information may include identification and paring information to connect with a JUUL Labs product, log files, modes, settings, durations, error rates, and other information that may be useful to enhance the connectivity between a compatible JUUL Labs product and the APP. We do not link this Device Usage information to your personal information in our systems and this information is transmitted in an anonymous form and in an encrypted manner. If you do not opt-in to the Usage Recording Feature, the App will not collect any device usage information. If you do opt-in and choose to save certain settings or save user profiles in a durable, continuing manner for future sessions regardless of JUUL Labs product, this information may be retained by JUUL Labs.
JUUL Labs utilizes information that is collected in various ways. Information collected helps our efforts to advance our customers’ and visitors’ online experience when visiting our Service. This ranges from accessibility, improving content, customer service, shopping checkout experience and overall Service satisfaction. We also use information we collect to assist with product development efforts, response to mandated legal notices, process purchases on the Websites, to provide you with products or services you request from us, to improve your overall experience with the Services, for internal analytics purposes, to troubleshoot technical difficulties and errors, to notify you about changes to our Services, and in any other way we may describe to you at the time you provide the information.
We may share your personal information with:
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
PLEASE NOTE: The products sold on this website are highly regulated by various governing agencies. It may become necessary to share the information that we collect with such agencies to comply with laws, a judicial proceeding, court order, or other legal requests.
The products that we sell on our Website are highly regulated and age-restricted. We are required and committed to preventing sales to anyone under the legal purchasing age. We will only send you marketing materials and information that encourage or facilitate a purchase of our products after you have certified that 1) you are a of legal purchasing age for the product you wish to purchase; 2) that you wish to be added to our mailing list for the purpose of receiving transactional offers and advertising from a tobacco-regulated company; and 3) that you understand that providing false information may constitute a violation of the law.
Before you can make a purchase, we will verify your age through a non-affiliated third-party company to perform an age and identify verification check for adherence to this requirement. We utilize these trusted verification services to verify the information that you provide and ensure that you qualify to access and purchase products from the Website. This process has been developed with the customer’s privacy in mind with detailed information neither shared nor accessible.
We may share, or we may permit third-party online advertising networks and other third-party services, to collect, information about your use of our Service over time so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or apps. Additionally, the Website utilize third-party sites to provide content to JUUL Labs customers such as social media features. These third-party sites may set cookies on your browser and/or obtain your IP address. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the Website, and other information. This information is used to display targeted ads on or through our Service or on other websites or apps, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. We do not permit third-parties to collect your identifiable information from the Website unless you provide it to them directly.
A. Information Collected Via Technology
An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. In some cases, your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. For example, we, or our service providers, may track your IP Address when you access JUUL Labs website to assist with ad targeting.
“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. Please read our Cookies Policy for more information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience with JUUL Labs. Persistent Cookies can be removed by following your Internet browser help file directions. In order to use our services offered through JUUL Labs, your web browser must accept Cookies. If you choose to disable Cookies, some aspects of JUUL Labs website may not work properly, and you will not be able to receive our services.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings.
A. Information Shared for Direct Marketing Purposes
If you are a California resident, you have the right to receive, once per year, free of charge:
1) the identity of any third-party company to which we have disclosed your personal information for that company’s direct marketing purpose on our Websites; and
2) a description of the categories of personal information disclosed. To request this information, please contact us at email@example.com.
B. Confirmation of Purchases
If you are a California resident who makes a purchase, we will make one phone call with an auto dialer and pre-recorded voice to the phone number you provide in order to confirm the order, pursuant to California law.
C. California Consumer Privacy Act Rights (“CCPA”)
As of January 1, 2020, verified California residents will have the right to:
For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
In order to make a request for disclosure California residents may contact us by visiting https://juul.force.com/us/s/ccpa or by calling (844)-668-6900. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
You may make a request up to twice within a 12-month period. We will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
We will not discriminate against you as a result of your exercise of any of these rights.
We do not provide personal information to third parties in exchange for monetary consideration, but during the past 12 months, we have disclosed data to certain third parties that provide us with services such as assisting with marketing, data analysis and security, which may fall under the definition of “consideration” and be considered a “sale” under the CCPA. Our Service is not intended for individuals under the age of 21. We do not knowingly collect or solicit any information from anyone under the age of 21 on this Service. Under CCPA, if you would like to instruct us not to sell your personal information, please visit our Do-Not-Sell web page at https://juul.force.com/us/s/ccpa. We do not sell personal information of individuals we actually know are less than 21 years of age. Once we receive your Do-Not-Sell request we will wait at least 12 months before asking you to reauthorize personal information sales.
During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.
|Categories of Information Collected||How We Collect Your Information||Business Purpose Use for Your Information||Third Parties Receiving Your Information|
|Protected Class Information|
|Electronic Network Activity|
|Inference from Above (Preferences, Characteristics, Behavior, Attitudes, Abilities, etc.)|
We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at firstname.lastname@example.org with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.
Modifying or deleting your information. If you have any questions about reviewing, modifying, correcting, or deleting your information, or if you want to remove your name or comments from our Website or publicly displayed content, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
Opt-out of App’s Usage Recording Feature. You may turn off the App’s Usage Recording Feature at time of download, or you may delete the App from your device.
How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of product or service-related communications (e.g., account verification, transactional communications, changes/updates to features of the service, technical and security notices).
Our Service is not intended for individuals under the age of 21. We do not knowingly collect or solicit any information from anyone under the age of 21 on this Service. In the event that we learn that we have inadvertently collected personal information from an individual under age 21, we will delete that information as quickly as possible. If you believe that we might have any information from an individual under 21, please contact us at firstname.lastname@example.org. Protecting the privacy of the underage is very important to us. Thus, if we obtain actual knowledge that a user is under 21, we will take steps to remove that user’s Personal Information from our databases.
We take the security of your information extremely seriously and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website. Our Service support the industry standard Secure Socket Layer (SSL) encryption which is applied to all data transmitted so it cannot be read by others. In addition, if you are using a shared computer to access the Website, we recommend that you log out of your account before ending your browser session. This will also ensure that your account will not be used by anyone other than yourself. Unfortunately, the transmission of information online is not completely secure. Although we do our best to protect all information collected through the Service, we cannot guarantee the security of your information collected and/or transmitted through the Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
We collect information in the form of the content that you submit during your use of JUUL Labs’ platforms and services, such as photos, comments, ratings and other information you choose to submit. We may also collect information about you and your friends, from any social network you may have connected from, in order to provide you with a more personalized experience. For instance, we may collect your user ID or profile information that you have permitted to be displayed through JUUL Labs in order to display you as a friend or in association with your profile and collections. When you order our products or services, you will need to submit your credit card or other payment information so that our service providers can process your payment for those products and services. If you choose to sign up to receive information about products or services that may be of interest to you, we will collect your email address and all related information. Additionally, we collect any information that you voluntarily enter, including Personal Information, into any postings, comments, or forums within the JUUL Labs community. For each of these Personal Information collections (or any below), we will ask for your consent and provide you with clarity before making any such collections. Additionally, you will have the option to opt out of any of these collections at any time and we will stop collecting such data from you.
A. Personal Information from Other Sources
We may receive Personal Information about you from other sources with which you have registered, companies who we have partnered with (collectively, “Partners”) or other third parties. We may associate this information with the other Personal Information we have collected about you.
B. E-mail and E-mail Addresses
If you send an e-mail to us, or fill out our “Feedback” form through JUUL Labs’ platforms, we will collect your e-mail address and the full content of your e-mail, including attached files, and other information you provide. We may use this e-mail address to contact you, for things such as notifications of limited-edition shop sales and other related information. You may indicate your preference to stop receiving further promotional communications as further detailed below.
C. Information you Post
You understand that when you use JUUL Labs, certain information you post or provide through JUUL Labs, such as your name, profile, comments, posts and ratings, may be shared with other users and posted on publicly available portions of JUUL Labs, including without limitation, chatrooms, bulletin and message boards, along with other public forums. Please keep in mind that if you choose to disclose Personal Information when posting comments or other information or content through JUUL Labs, this information may become publicly available and may be collected and used by others, including people outside the JUUL Labs community. We will not have any obligations with respect to any information that you post to parts of JUUL Labs’ platforms available to others, and recommend that you use caution when giving out personal information to others in public forums online or otherwise. We also share the information you publish with other third parties.
D. SMS Terms of Service
When you opt in to receive marketing messages, we will send you an SMS message to confirm your sign up.
Upon completing 2-Factor Authentication, users will be automatically enrolled in Transactional message SMS.
You can cancel the SMS service at any time. Just reply “STOP”. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us.
If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.
Users must explicitly elect to opt in to JUUL Marketing SMS.
We are able to deliver messages to the following mobile phone carriers:
Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile.
Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless).
This list may change without warning and without notice to you.
As always, message and data rates may apply for any messages sent to you from us and to us from you. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
As with any of its programs, JUUL Labs, Inc. may discontinue this program at any time and without notice to you.