JUUL Labs, Inc.

Privacy Policy

Effective Date: January 1, 2020

Welcome to www.JUUL.com or www.JUULLabs.com offered by JUUL Labs, Inc. (“JUUL Labs”, “us” or “we”). This privacy policy addresses how information is collected, stored, and utilized through our website, www.Juul.com and/or www.JUULLabs.com (individually a “Website” or collectively the “Websites”) and any mobile application we may offer in the future which is linked to this Policy (the “App”) (collectively, the “Services”). By accessing or using our Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information, as applicable, as described in this Privacy Policy and the Websites’ respective Terms of Service.

JUUL Labs reserves the right to change this Privacy Policy. See the section captioned “Changes to this Privacy Policy” below.

1. Information Collected

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

We and our third-party partners, automatically collect certain types of usage information when you visit our Website, use our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technologies (collectively, “tracking technologies”). For example, we may collect information such as your domain name, browser type, operating system, IP address, web pages viewed while visiting our site, links clicked, length of time spent on our Service, and reference website from which you accessed the Website. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Website and to understand more about the demographics of our users. In gathering this information, we are able to enhance your experience when visiting our Website (including keeping your preferences and items placed in your shopping cart between visits) and to provide custom, personalized content and information, including targeted content and advertising. These cookies do not contain or track sensitive information such as your payment information. You may set your browser to not accept cookies; however, some features of the Websites may not function properly without the use of cookies. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

If you download and use a mobile App to access our Service, we automatically collect certain types of information about your device and usage in several ways. When you download and use the App, JUUL Labs will automatically receive certain information, about which JUUL Labs products that are connected to the App, your mobile device and your usage of the App, such as the device operating system and version and information regarding your use of the App, such as the time spent using the App, which features of the App you access and use, and error messages but not specific identifying information about you. JUUL Labs may modify the information that it receives from the App at any time and will provide you notice of such changes by alerting you of a change to the Privacy Policy.

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.

2. Use And Sharing Of Information Collected

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.

We also may disclose information that has been collected where we believe it is necessary to investigate, prevent, or take action regarding underage use or purchase of JUUL Products, illegal activities, suspected fraud and/or counterfeit, situations involving potential threats to the safety of any person, violations of our Terms of Service or Privacy Policy, or as evidence in litigation in which JUUL Labs is involved.

3. Age Verification

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.

In some cases, we may not be able to verify your age and/or identity through a verification service. If we are unable to verify your age with the requested information, we require that you verify your identity through a third-party service called Berbix. Before proceeding, however, we will seek your agreement and consent via a dialogue box that will appear on our JUUL Website. Berbix will: collect an image of your face that you provide through our JUUL Website; collect a photo or scan of your face as it appears on an identification document; and employ facial recognition technology to verify your identity and age. Berbix provides us with a report of its findings. JUUL Labs does not collect, retain or possess the original photos or scans that you submit to Berbix. By using Berbix, you are submitting your photos and identification documents for verification directly to Berbix, you are agreeing to share your identification with Berbix, and you agree that Berbix is solely responsible for any use or loss of data. To learn how Berbix will collect and use your information, please refer to Berbix’s Privacy Policy and Terms of Service.

4. Third Party Tracking And Online Advertising

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

As you use JUUL Labs’ platforms and services, certain information may also be passively collected and stored on our or our service providers’ server logs, including your Internet protocol address, browser type, and operating system. We also use Cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed, or on which of the advertisements displayed on JUUL Labs website you clicked. This type of information is collected to make JUUL Labs website and solutions more useful to you and to tailor the experience with JUUL Labs website to meet your special interests and needs.

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.

5. Your California Privacy Rights

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 dataprivacy@juul.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
Identifiers
  • Individuals submitting information to us and/or
  • Information we automatically collect from site visits and/or
  • Employment information/applications
  • Performing Services for You
  • Transaction Audits
  • Block and remove fraudulent and unverified users
  • Functionality debugging/error repair
  • Ad customization
  • Internal research and development
  • Quality Control
  • Compliance with Federal, State and Local regulations
  • Service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners)
  • Sensitive Information
  • Individuals submitting information to us and/or
  • Employment Applications and/or
  • Employee Information
  • Transaction Audits
  • Security detection, protection and enforcement
  • Functionality debugging/error repair
  • Ad customization
  • Performing services for you
  • Internal research and development
  • Quality Control
  • Compliance with Federal, State and Local regulations
  • Service Providers (such as payment processors, employee benefits partners)
  • Protected Class Information
  • Individuals submitting information to us and/or
  • Employment Applications and/or
  • Employee Information
  • Transaction Audits
  • Security detection, protection and enforcement
  • Performing services for you
  • Internal research and development
  • Quality Control
  • Compliance with Federal, State and Local regulations
  • Service Provider (such as employee benefits partners)
  • Commercial Information
  • Individuals submitting information and/or
  • Information we automatically collect from site visitors
  • Performing Services for you
  • Transaction History and Auditing
  • Security detection, protection and enforcement
  • Functionality debugging/error repair
  • Ad customization
  • Performing services to you
  • Internal research and development
  • Quality Control and Assurance
  • Product Improvement
  • Compliance with Federal, State and Local regulations
  • Service providers (such as marketing partners, shipping partners)
  • Electronic Network Activity
  • Information automatically collected from site visitors
  • Transaction Audits
  • Security detection, protection and enforcement
  • Functionality debugging/error repair
  • Ad customization
  • Performing services for you
  • Internal research and development
  • Quality control
  • Service providers (such as payment processors, security detection)
  • Audio/Video Information
  • Individuals submitting information and/or
  • Information we collect for security purposes
  • Transaction Audits
  • Security detection, protection and enforcement
  • Functionality debugging/error repair
  • Ad customization
  • Performing services for you
  • Internal research and development
  • Quality control
  • Service providers (such as payment processors, security detection)
  • Biometrics
  • Individuals submitting information and/or
  • Information we collect for security purposes
  • Transaction Audits
  • Security detection, protection and enforcement
  • Performing services for you
  • Compliance with Federal, State and Local regulations
  • Service providers (such as payment processors, marketing partners, shipping partners)
  • Geolocation
  • Information we automatically collect from site visitors
  • Transaction Audits
  • Security detection, protection and enforcement
  • Functionality debugging/error repair
  • Ad customization
  • Performing services for you
  • Internal research and development
  • Quality Control
  • Service providers (such as marketing partners)
  • Inference from Above (Preferences, Characteristics, Behavior, Attitudes, Abilities, etc.)
  • Internal analytics
  • Information we automatically collect from site visitors
  • Information submitted by individuals
  • Transaction Audits
  • Security detection, protection and enforcement
  • Functionality debugging/error repair
  • Ad customization
  • Performing services for you
  • Internal research and development
  • Quality Control and Assurance
  • Service providers

  • 6. Notice To Nevada Residents

    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 dataprivacy@juul.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

    7. Rights With Respect To Your Data

    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 dataprivacy@juul.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).

    8. Privacy Of The Underage

    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 dataprivacy@juul.com. 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.

    9. Users Outside Of The U.S.

    Your information collected through our website may be stored and processed in the United States or any other country in which JUUL Labs or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which JUUL Labs or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

    10. Third-party Websites

    Our Service may contain links to websites operated by third parties. This Privacy Policy does not apply to these third-party website or services. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms & conditions and that we do not accept any responsibility or liability for their policies. Links should be clicked at your own risk, and it is your sole responsibility to review the applicable privacy policy and terms and conditions of any third-party website accessed.

    11. Security

    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.

    12. SMS Short Code And Partner Technology Privacy Policy

    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.

    13. Changes To This Privacy Policy

    We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the Privacy Policy in a material manner, we will let you know and update date at the top of this page. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.

    14. Contact Us

    If you have any questions about this Privacy Policy, please contact us at dataprivacy@juul.com.