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JUUL LABS, INC.
Effective Date: June 18, 2024
This privacy notice (“Corporate Privacy Notice”) applies to personal information processed by Juul Labs, Inc. (“Juul Labs,” “we,” “us,” or “our”) when engaging with us on our corporate websites including www.juullabs.com, www.juullabsretailer.com, or www.juullabsscience.com (collectively, the “Corporate Sites”), or other online informational offerings owned or operated by Juul Labs (collectively, the “Services”). Our Corporate Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information when you engage with us through the Corporate Sites and to help you understand and exercise your privacy rights.
As used in this Corporate Privacy Notice, “personal information” has the meaning given to it under the law where you live, but typically refers to information that can be used to identify you as an individual; meanwhile our activities taken with respect to your personal information are referred to as “processing.” For residents of California and other US states with specific privacy rights, additional disclosures are available below.
You can also download a copy of the policy.
This Corporate Privacy Notice only applies to the Corporate Sites. Our Corporate Sites provide information about our work to offer adult smokers an alternative to combustible cigarettes and, in so doing, reduce the harm associated with tobacco. The Corporate Sites also provide information about, and our Services support, our work to combat the serious problem of underage use of vapor products directly, and through our authorized retailers.
We have an independent, age-restricted website through which we offer our products to eligible adult smokers and other users (the “E-Commerce Site”). This Corporate Privacy Notice only describes the personal information we collect and process through the Corporate Sites; the data practices of our E-Commerce Site are described by the E-Commerce Site’s Privacy Policy.
We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, resume, cover letter, or other expression of interest, we will collect and use your information to assess your qualifications and potential employment pursuant to the terms of the Worker and Applicant Privacy Notice, not this Corporate Privacy Notice.
Changes to our Corporate Privacy Notice. We may revise this Corporate Privacy Notice from time to time in our sole discretion. If there are any material changes to this Corporate Privacy Notice, we will notify you as required by applicable law, such as by sending you an email or announcing the change to policy on our Services. If you continue to use the Corporate Sites after the new Corporate Privacy Notice takes effect, we will assume you have read and acknowledged the new terms.
The categories of personal information we collect depends on how you interact with us, our Corporate Sites, and the requirements of applicable law. We collect information that you provide to us directly, information we obtain automatically when you use our Services, and information from other sources as described below.
Information You Provide to Us
Policy Regarding Cookies and Similar Technologies
Our uses of these Technologies fall into the following general categories:
Other Sources
Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings. If you are a research professional who has submitted a proposal to our IIR Program, we may collect or validate personal information if and as applicable, such as your institutional affiliation, license information, past publications, and other due diligence related information from various sources.
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
Provide Our Services.
We use your information to fulfil our contract with you and provide you with our Services, such as:
Administrative and Business Purposes.
We use your information for various administrative purposes, such as:
With Your Consent
We may use your personal information for other purposes that are clearly disclosed to you at the time and in the context that you may choose to share it with us, as requested by you, at your direction or otherwise with your consent.
Other Purposes
We also use your personal information for other purposes as permitted by applicable law, including to create de-identified and/or aggregated analyses.
We may disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
To Provide our Services
We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, business analytics, hosting, customer service, and related services. We may also share your information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and as described in the Your Privacy Choices and Rights section below.
To Protect Ourselves or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
In the Event of Merger, Sale, or Other Asset Transfers
If we are involved in an actual or proposed merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another commercial entity, your information may be disclosed, sold, or transferred as part of such a transaction, as permitted by law and/or contract.
Your Privacy Choices
The privacy choices you may have about your personal information are determined by applicable law and described below.
Your Privacy Rights
The privacy rights you may have about your personal information are determined by applicable law and described below.
If you would like to exercise any of these rights, please Contact Us at any time, or as otherwise instructed in the additional privacy notices provided at the time we collect your personal information. We will process such requests in accordance with applicable laws and will not discriminate or retaliate against you for the exercise of any of these rights. For additional rights applicable to residents of certain US states, please refer to the disclosures below.
We take steps to ensure that your information is treated securely and in accordance with this Corporate Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of your personal information. By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically, for example by posting a notice on our Services, by mail, or by sending an email to you.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
We store the personal information we collect as described in this Corporate Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.
The Services are not directed to minors (or any individual under the age of 21), are designed to discourage individuals under 21 from engaging with our Services and from accessing the Corporate Sites, and we do not knowingly collect personal information from, or otherwise interact with, individuals under the age of 21.
Protecting minors is important to us. If you are a parent or guardian and believe your child has submitted personal information through the Corporate Sites without your consent, and you wish to have that information modified or deleted, or you may Contact Us at any time as set forth below. If we become aware that an underage individual has provided us with personal information in violation of our policies, compliance obligations or applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.
The Corporate Sites may contain links to other Juul Labs websites or terms which govern those sites or activities. In addition, the Corporate Sites may link to, or be referenced by websites/applications that are operated by third parties and not controlled by us. We encourage you to read the privacy policy of each website or application you visit. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of any third-party website or application. Providing personal information to third-party websites or applications is at your own risk.
Juul Labs is the controller of the personal information we process under this Corporate Privacy Notice. If you have any questions about our privacy practices or this Corporate Privacy Notice, or to exercise your rights as detailed in this Corporate Privacy Notice, please:
Make an online request by visiting our Privacy Portal
Email us at dataprivacy@juul.com
Call us at 1-855-509-5885
Write to us at:
Juul Labs, Inc.
Attn: Chief Compliance Officer
1000 F Street NW
Washington, DC 20004
This Notice at Collection and Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time (collectively, “Applicable State Laws”).
Personal Information we Collect and Share
As more fully described in the section titled Personal Information We Collect, the sources from which we collect personal information include directly from you when you interact with us, automatically from you when you use our sites and Services (for example through cookies and other Technologies), from third parties (for example, from third-party referrals).
Depending on how you use our Services, the information we may have collected about you, as well as the categories of third parties with whom we have shared this information, are described in the table below.
Personal Information Collected by Juul Labs
Third Parties to Whom Personal Information May Disclosed for a Business Purpose
Third Parties with Whom Personal Information May be Shared
Personal Information Collected by Juul Labs
Third Parties to Whom Personal Information May Disclosed for a Business Purpose
Third Parties with Whom Personal Information May be Shared
Personal Information Collected by Juul Labs
Third Parties to Whom Personal Information May Disclosed for a Business Purpose
Third Parties with Whom Personal Information May be Shared
Personal Information Collected by Juul Labs
Third Parties to Whom Personal Information May Disclosed for a Business Purpose
Third Parties with Whom Personal Information May be Shared
Personal Information Collected by Juul Labs
Third Parties to Whom Personal Information May Disclosed for a Business Purpose
Third Parties with Whom Personal Information May be Shared
Use of Personal Information
We may use or disclose the personal information we collect for the purposes outlined in Use of Information above. Where required under applicable law, we will not collect additional categories of personal information or use the personal information we have collected for materially different, unrelated, or incompatible purposes without first providing you notice.
Sales/Sharing of Personal Information
For purposes of certain laws, Juul Labs does not “sell” personal information, nor do we have actual knowledge of any sale of personal information as the term “sell” is commonly understood. We may share information with third parties for the purpose of analyzing traffic on the Corporate Sites as described above. You may limit such sharing by adjusting your browser settings to send a GPC signal, or by Contacting Us.
Retention of Personal Information
We store the personal information we collect as described in our Corporate Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data. We endeavor to retain all such personal information in accordance with legal requirements.
Additional Privacy Rights for Residents of Certain States