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Effective Date: September 16, 2020
JUUL Labs, Inc. (“Juul Labs,” “we,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how personal information you provide to our website, www.juullabsscience.com or in connection with our Investigator-Initiated Research (“IIR Program”) is collected, used, stored and disclosed by Juul Labs. This Privacy Policy applies only to our website, www.juullabsscience.com, any other website that links to this Policy, and any other data we collect in relation to the IIR Program, including via the Submission form. JUUL Labs, Inc. is the controller and responsible for your information.
If you wish to contact us in relation to this Privacy Policy, please contact: dataprivacy@juul.com
Your use of the juullabsscience.com website and/or provision of your personal information to us in connection with the IIR Program constitutes your consent to the use, storage, processing and transfer of that information in accordance with this Privacy Policy.
You can also download a copy of the policy.
Here are the ways you may provide the information, the types of information you may submit, and how we may use the information.
Personal Information you provide directly to us:
IIR Program-related information. You may choose to provide personal information including: your name, credentials, organization, phone number, email address, written agreement, your research study, your communications with us, and any other information you submit to us when you submit a research proposal, participate as an investigator in the IIR Program, communicate with us about the IIR Program, or participate as a member of an institution engaged in IIR research. We use this information to run and manage the IIR Program, as well as to communicate directly with you.
Contact Us. If you email us through the “Contact Us” link on this site, we ask you for information such as your name and email address so we can respond to your questions and comments. If you use the “Contact Us” feature of this site to provide us with information other than personally identifying information, including suggestions about the site, and any other such information, that information will belong to us and may be used, reproduced, modified, distributed and disclosed by us in any manner we choose, without paying compensation to you. Do not send us any product or advertising ideas.
Non-Personal and Other Information we collect automatically:
You also should be aware that we automatically collect certain statistical information about our site visitors, such as the IP address or unique identifier of your device, the number and frequency of visitors to certain parts of the site. This data is used only in the aggregate and does not include any personally identifying information. Aggregate and non-personal information does not relate to a single, identifiable visitor. It tells us such things as how many users visited our site and the pages accessed. By collecting this information, we learn how to best tailor this website to our visitors.
We do not use cookies on the site, but we may use similar technology to collect aggregate (non-personal) information about Site usage by all of our visitors. We carefully restrict the ability of third parties to collect information about a consumer’s online activities over time and across different websites when he or she uses our website. For instance, we use Google Analytics to recognize you and link the devices you use when you visit our site on your browser or mobile device, log in to your account, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our website. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On at https://tools.google.com/dlpage/gaoptout/.
This site does not currently use technology that recognizes a ‘do not track’ signal from your web browser.
We do not sell, rent or otherwise disclose personal information about our website visitors, except as described here. We may disclose information about you if you request or authorize it or to help complete a transaction for you. We also may share information provided by our website visitors with corporate affiliates or with service providers we have retained to perform services on our behalf. These service providers are restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, to protect your, our, or others’ rights, property or safety, or to enforce our agreements.
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided through this website in a manner that is consistent with this Privacy Statement.
We may disclose de-identified, non-private, or aggregated, information, such as usage statistics of our website, to our affiliates and third parties.
We do not share your information with any third party for their direct marketing use.
This Site is not designed nor intended to be attractive to, or used by individuals under the age of 21. In the United States, we do not knowingly collect or solicit any information from anyone under the age of [21]. In the EU, we do not knowingly collect or solicit any information from anyone under the age of 18. 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 are under [21 or the legal purchasing age] please do not submit any information to us. If you are aware of someone underage submitting information to us, please contact us at dataprivacy@juul.com.
We may provide links to other websites for your convenience and information. These sites operate independently from www.juullabsscience.com. These sites may have their own privacy statements in place, which we strongly suggest you review if you visit any linked websites. Unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policy applicable to that site. To the extent any linked websites you visit are unrelated to Juul Labs or its affiliates, we are not responsible for their content or any use of the sites.
We maintain administrative, technical and physical safeguards for this website to protect against unauthorized disclosure, use, alteration or destruction of the personal information you provide on the site. However, no method of electronic transmission or storage is 100% secure. If we receive instructions using your log-in information we will consider that you have authorized the instructions, so please keep your log-in information secure.
You can update, amend or delete your information at any time by logging into your account or by contacting us using the information below.
You can exercise your choices with respect to Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.
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) by matching information you provide to information in our records and will use that information only for that purpose. If you request specific information collected about you or deletion of information, we may ask you to sign a declaration under penalty of perjury attesting to your identify. 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://support.juul.com/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, depending upon which Websites you have visited, 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 |
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Sensitive Information |
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Protected Class Information |
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Commercial Information |
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Electronic Network Activity |
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Audio/Video Information |
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Biometrics |
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Geolocation |
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Inference from Above (Preferences, Characteristics, Behavior, Attitudes, Abilities, etc.) |
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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.
For individuals within the United Kingdom (“UK”) and European Economic Area only. Under the GDPR, in certain circumstances, you have the right to: (a) request access to any personal information we hold about you and related information, (b) obtain without undue delay the rectification of any inaccurate personal information, (c) request that your personal information is deleted provided the personal information is not required by us for compliance with a legal obligation under UK, European Union (“EU”), or EU Member State law or for the establishment, exercise, or defense of a legal claim, (d) prevent or restrict processing of your personal information, except to the extent processing is required for the establishment, exercise or defense of legal claims; and (e) request transfer of your personal information directly to a third party where this is technically feasible.
In addition, where you believe that 1stdibs.com has not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.
If you wish to exercise your UK or European data subject rights, you have the following options:
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.
Purpose/Activity
Lawful basis for processing (including basis of legitimate interest)
To register you as an investigator in the IIR Program and account creation, including validation of your selection and qualification documentation by Juul Labs Scientific Affairs Staff
Performance of a contract with you, for our legitimate interests (to manage and administer the IIR Program)
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 the IIR Program, effectively provide services and keep our records updated)
To administer and manage your participation in the IIR Program (including submission and approval of study proposals, managing proposals (including sharing proposals with Juul Labs’ multi-disciplinary review team) managing and administering IIR written agreements, 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 research studies and running the IIR Program) with your Consent
To facilitate investigator-initiated research studies via the IIR Program, including on the website.
Performance of a contract with you; Necessary to comply with a legal or regulatory obligation
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 reorganization or group restructuring exercise); Necessary to comply with a legal obligation
Information collected through the website will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Website, you consent to such transfer to, storage in and processing within the United States. We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our online information practices. We will post a prominent notice on this site to notify you of any significant changes to our Privacy Statement and indicate at the top of the statement when it was most recently updated.
If you have any questions or comments about our information practices, Contact Us through email at dataprivacy@juul.com or write to:
JUUL Labs, Inc.
560 20th Street
San Francisco, CA 94107