Welcome to www.JuulVapor.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.Juulvapor.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 regards 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:
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).
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:
Third-party vendors, service providers, contractors and agents that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving advertisements, providing mailing services, providing financial services, web hosting, or providing analytic services. This sharing is only done so when those entities are performing functions solely on our behalf and they are not permitted to store such information except as needed to perform our work or as required by law;
When you post content to any public area of our externally facing platforms, including social media pages or blog, this information may be visible to the public and we may publish this information on our website and social media pages along with some of your personal information such as your first name, last initial, and state of residence;
With your consent, to third parties who may send you offers and information about products and services we think you may enjoy;
Other companies and brands owned or controlled by JUUL Labs and other companies owned by or under common ownership as JUUL Labs, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy;
Other parties in connection with a company transaction, such as a merger, corporate restructuring, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Services; and/or (c) to exercise, investigate, or protect the rights, property, or personal safety of JUUL Labs, our visitors, or others.
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 from a product specific newsletter mailing list, 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 might not be able to verify your age and/or identity through their verification service. If you are unable to verify your age with the requested information, you will be requested to upload a copy of your government ID that our team can manually verify your date of birth. Photo ID's are uploaded to our third party partner’s secure database and we simply process the result that they provide – we do not receive a file with your ID to be stored on our servers or database.
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.
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
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 legal@juul.com.
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.
6. 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 legal@juullabs.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).
7. Children’s Privacy
Our Service is not intended for individuals under the age of 18. We do not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at legal@juullabs.com.
8. 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.
9. Third Party Websites
Our Service may contains 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.
10. 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.
11. 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.
12. Contact Us
If you have any questions about this Privacy Policy, please contact us at legal@juul.com.
Welcome to UserTesting.juul.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 UserTesting.juul.com (the “Website”). It also applies if you have signed up to the JUUL User Testing Program or have been recruited to participate in a JUUL User Feedback Study. If you wish to contact us in relation to usertesting.juul.com, the JUUL User Testing Program or a JUUL User Feedback Study, please contact: usertesting@juul.com.
JUUL Labs, Inc. is the controller and responsible for your information.
JUUL Labs reserves the right to change this Privacy Policy. See the section captioned “Changes to this Privacy Policy” below. The Website and our product testing program are not intended for children and we do not knowingly collect data relating to children. For more information, see paragraph 9.
1. Information Collected JUUL Labs holds our customer base in the highest regards and is dedicated to providing the best experience on our Services. In order to offer an enjoyable and premium experience on our Website, the JUUL User Testing Program or a JUUL User Feedback Study, 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:
Information that you provide to us We may collect personal information that you provide to us directly, such as your name, phone number, location, postal address, and e-mail address when you when you register on our Website (to sign up to the JUUL User Testing Program), are recruited to participate in a JUUL User Feedback Study, sign up for our mailing list, or otherwise communicate with us. Account creation is required when joining the JUUL User Testing Program. We may also collect any communications between you and JUUL Labs and any other information you provide to JUUL Labs or our other JUUL companies.
If you have signed up to the JUUL User Testing Program, we may collect information directly from you when you participate in one of our JUUL User Feedback Studies. Where the information you provide may indicate details about your health (eg, an adverse health event), this is known as your special category personal data. We will only collect such data with your consent.
Information automatically collected We and our third party partners, automatically collect certain types of usage information when you visit our Website, 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. 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 Website 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 fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service but we will notify you if this is the case at the time.
2. Use and Sharing of Information Collected JUUL Labs utilizes information that is collected in various ways but principally to enable your participation in the JUUL User Testing Program, and if you have the opportunity to be recruited, a JUUL User Feedback Study. We set out below the purposes/activities for which your information is used at paragraph 4.
Information collected helps our efforts to develop quality products and advance our customers’ experience when using our products and services, or visiting our Website. This ranges from device functionality and performance, accessibility, improving content, customer service and overall service satisfaction. The information we collect assists with product development efforts, response to mandated legal notices, to provide you with products or services you request from us, to improve overall experience with our products and 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 (for the purposes set out below at paragraph 4) with: • Third-party vendors, service providers, contractors and agents that perform services on our behalf, as needed to carry out their work for us, which may include hosting the Website, providing mailing services, providing financial services, or providing analytic, research and development services. This sharing is only done so when those entities are performing functions solely on our behalf and they are not permitted to store such information except as needed to perform our work or as required by law; Please note: we currently use trusted US processors to host our Website and manage the delivery and collection of testing materials. • With your consent, to third parties who may send you offers and information about products and services we think you may enjoy; • Other companies and brands owned or controlled by JUUL Labs and other companies owned by or under common ownership as JUUL Labs, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way as we can under this Privacy Policy; • Other parties in connection with a company transaction, such as a merger, corporate restructuring, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Services; and/or (c) to exercise, investigate, or protect the rights, property, or personal safety of JUUL Labs, our visitors, or others. This may include tax authorities.
We may share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
If you have joined the JUUL User Testing Program and have had the opportunity to participate in a JUUL User Feedback Study, we may share your information, including the results of product tests you may participate in, with other JUUL companies, in order to effectively run our product development and research program. PLEASE NOTE: The products sold on our websites or for testing 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.
3. How we use your Personal Data 3.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 3.1.1 Where we need to perform the contract we are about to enter into or have entered into with you. This includes where you have agreed to the terms and conditions of participation in the JUUL User Testing Program. 3.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 3.1.3 Where we need to comply with a legal or regulatory obligation. 3.2 Generally we do not rely on consent as a legal basis for processing your personal data other than where we collect your special category personal data or in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.
4. The purposes for which we will use your personal data 4.1 We have set out below, in a table format, a description of all the ways we may use your information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 4.2 Note that we may process your information for more than one lawful ground depending on the specific purpose for which we are using your information.
Purpose/Activity
Lawful basis for processing including basis of legitimate interest
To register you as a participant in the JUUL User Testing Program and account creation
Performance of a contract with you, for our legitimate interests (to manage and administer our Testing Program)
To process and deliver testing materials if you are recruited to participate in a JUUL User Feedback Study
Performance of a contract with you; Necessary for our legitimate interests (to manage and administer our Feedback Studies)
To manage our relationship with you which will include: communicating with you (such as to send you email messages); notifying you about changes to our terms or privacy policy; we may also send you service-related emails or messages (e.g., account verification, change or updates to features of the Website, technical and security notices)
Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to manage and administer our testing program, effectively provide products and services and keep our records updated)
To administer and manage your participation in the JUUL User Testing Program (including sending you invites for a JUUL User Feedback Study; your participation in product tests via Feedback Studies; the distribution and collection of testing materials; gathering feedback; and, managing your registration and account)
Performance of a contract with you; Necessary to comply with a legal or regulatory obligation; Necessary for our legitimate interests (for conducting product testing, research and development; ensuring product performance and customer satisfaction; product liability and insurance requirements including product recall; marketing and advertising substantiation, with your Consent
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To provide you with relevant website content and advertisements to you and measure or understand the effectiveness of the marketing we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation
Age verification (for more details see further details at paragraph 5)
Performance of a contract with you; Necessary to comply with a legal obligation
You may receive an invitation to join the JUUL User Testing Program, if you have purchased a product from us and have opted in to our mailing list (via juul.co.uk). For information on how to manage your preferences, please see paragraph 8.
5. Age Verification The products that we sell and develop are highly regulated and age-restricted. We are required and committed to preventing sales to or testing by anyone under the legal purchasing age and we verify your age before you are eligible to make a purchase or be contacted about our testing program. 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, opportunities and advertising from a tobacco-regulated company; and 3) that you understand that providing false information may constitute a violation of the law.
6. Third Party Tracking and Online Advertising When you visit a JUUL website, 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 services over time so that they may play or display ads that may be relevant to your interests on our services as well as on other websites or apps. Additionally, we may 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 a 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. 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 may not permit third parties to collect your identifiable information unless you provide it to them directly.
7. Your California Privacy Rights 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 legal@juul.com.
8. Rights with Respect to Your Data Under certain circumstances, you have rights under European data protection laws in relation to your information. Full details of these rights can be found within the Glossary of our UK Privacy Policy at juul.co.uk/privacy-policy.
Request access to your information, including a copy of that information. Request correction of your information e.g. if it is incomplete or inaccurate . Modifying or deleting your information where there is no good reason for us continuing to process it Objecting to the processing of your information where we are relying on a legitimate interest. Request restriction or transfer of processing your information (in a machine-readable format). Right to withdraw your consent.
If you have any questions about exercising your rights, you can contact us directly at usertesting@juul.com. We may not be able to modify or delete your information in all circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your information (or to exercise any of your other rights).
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please note: you have the right to complain to your local data protection authority about our handling of your personal data. In the United Kingdom this is the Information Commissioner's Office (ICO), the supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
How to control your communications preferences: If you are on our mailing list (via juul.co.uk), please see the Privacy Policy at juul.co.uk for information on how to stop receiving permitted marketing messages.
[You can also stop receiving emails from usertesting@juul.com by clicking on the link provided in such communications.]
We make every effort to promptly process all 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).
9. Children’s Privacy Our service is not intended for individuals under the age of 18 and there are age criteria in relation to participation in the JUUL User Testing Program (21+). We do not knowingly collect or solicit any information from anyone under the age of 13. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at legal@juul.com.
10. 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 agree with 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.
We have safeguards in place within our group of companies to protect your information where it is transferred outside of the EEA. This includes only transferring your information to countries that have been deemed to provide an adequate level of protection by the European Commission. We may also use specific contracts with our group companies, or with service provides, which are approved by the European Commission which give your information the same protection it has in Europe. For further details, see: European Commission: Model contracts for the transfer of personal data to third countries . Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield .
11. How long will you use my personal data for? 11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any regulatory, legal, accounting, or reporting requirements. 11.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 11.3 In some circumstances you can ask us to delete your data: see the “deleting” legal right above for further information. 11.4 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. Third Party Websites Our Service may contains 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.
13. 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.
14. 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 upload a new version to the Website and update the date at the top of this page. If you object to any changes, you may close your account.
15. Contact Us If you have any questions about this Privacy Policy, usertesting.juul.com or the JUUL User Testing Program, please contact us at usertesting@juul.com.