Juul Labs, Inc. Notice At Collection and U.S. State Privacy Notice

Last Updated: 12/17/2024

This Notice at Collection and US State Privacy Notice is for residents of U.S. states that have adopted comprehensive privacy legislation and others that may come into effect from time to time. If you live in a state with privacy laws (“State Privacy Laws”) that apply to Juul Labs, Inc. (“JLI,” “we,” “us” and “our” ), this Notice at Collection and U.S. State Privacy Notice (“Notice”), together with our Global Privacy Notice applies to you.

Our Global Privacy Notice explains how we collect, use, and disclose personal data (also known as personal information), as well as our online marketing practices. As required by certain State Privacy Laws, we also use the table below to illustrate our data practices over the past twelve months.

Collection, Use and Disclosure of Personal Information for Business Purposes

Category of Personal Information	Source of Collection	Purpose of Collection and Use	Third Parties to Which Personal Information is Disclosed
Identifiers	From you	To verify age and eligibility of individuals to be our customers; To provide our Services; For our administrative purposes (including security, compliance enforcement, fraud detection and protection, and to improve our Services); To act on your instructions and to process your requests, orders, and transactions (including provide customer service to you); To market our products to current adult smokers, and To comply with law, ensure compliance with our policies and procedures, and enforce our rights and the rights of others.	Business partners Service providers Advertising networks Internet service providers Data analytics providers Government entities Social networks
Commercial Information	From you	To process your payments and to fulfill orders placed through our E-Commerce Site.	Service providers Business partners Affiliates Government entities
Internet or other Electronic Network Activity	From you	To collect analytics, serve advertising, or support and deliver Services.	Service providers Business partners Affiliates Internet service providers Data analytics providers Government entities Operating systems and platforms
Geolocation Data	From you	To support requested JUUL App and JUUL2 Device features.	Service providers
Sensory Data	From you	To support customer service requests made by phone.	Service providers
Protected Characteristics	From you and from third parties	To manage regulatory obligations related to product safety and public health.	Service providers Affiliates Government entities
Sensitive Personal Information	From you and from third parties	To manage regulatory obligations related to product safety and public health.	Service providers Affiliates Government entities

Sensitive Personal Information

We may collect sensitive personal information as defined by certain State Privacy Laws when working to satisfy our regulatory obligations. We do not process sensitive personal information for purposes unrelated to satisfying our compliance obligations and do not use sensitive personal information to profile or infer characteristics about you or other individuals. Please see our Consumer Health Privacy Notice for more information about sensitive personal information we may collect.

Retention of Personal Information

We store the personal information we collect for as long as necessary to fulfill the purpose(s) for which it was collected and for other purposes described in this Notice and our Global Privacy Notice.

We may also disclose certain categories of personal information in conducting online analytics activities. While we do not disclose your personal information for money, these activities may be considered “sales,” or “sharing,” under certain State Privacy Laws. The table below provides more information about these practices.

Category of Personal Information that is “Shared” or “Sold”	Categories of "Third-Party Recipients”
Internet or Other Electronic Activity Information	Analytics providers

We do not have actual knowledge that we “sell” or “share” personal information about consumers under 21 years of age either as those terms are commonly understood or as they are defined under certain State Privacy Laws.

Submitting a Privacy Request

Opt-Out of “Sale” or “Sharing” Although we do not “sell” your personal information as the term “sale” is typically understood, we may “share” information with analytics providers to understand how visitors use our Sites and to serve you ads on and off our Sites. Where applicable, we will offer you a choice about whether to accept or opt-out of certain Tracking Technologies, the use of which may constitute a “sale” or “share” of personal information under State Privacy Laws. Please note that Tracking Technologies are browser and device specific. Any request to opt-out or reject the use of these Tracking Technologies will only be linked to a browser identifier and will need to be independently managed across different browsers and devices.

You may also exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). You can learn more about the GPC here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access the E-Commerce Sites, you will need to renew your opt-out request. (Note that while we honor the GPC, we do not listen for or respond to older, Do Not Track (“DNT”) technologies that users may set in certain web browsers.
Access, Correction, and Deletion. You have the right to (1) request to know more about and access your personal information, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, correction, or deletion of your personal information, please Contact Us. We may verify your identity by asking you to provide information related to your recent interactions with us, such as your name, email address, or phone number. If you are an account holder, you can also delete your account and personal information in it, by logging in through the US E-Commerce Site and exercising your preferences through your profile.
Nondiscrimination. We will not discriminate against you for exercising your privacy rights.
Authorized Agents. Depending on your state of residence, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a consumer, please Contact Us.
Appeal. If we deny your request, you may appeal our decision by Contacting Us. If you have concerns about the result of an appeal, you may contact the attorney general or other authority specified in the US State Privacy Laws in the state where you reside.

Contact Us

Make an online request by visiting our Privacy Center.

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

Other Privacy Choices

You can also manage the way that we use your personal information by exercising applicable privacy rights and choices as described in our Global Privacy Notice.

Notice of Financial Incentive

Our commercial and marketing activities are exclusively designed for, and meant only to offered to, age-verified adult smokers (“Marketing Programs”). Because these Marketing Programs involve the collection of personal information, they may be considered a “financial incentive” program under certain Applicable State Laws. The value of any personal information that may be provided by adults when signing up for any such Marketing Program would be related to the value of any discounts that are received by the participant, less our costs related to administering such Marketing Program(s). Our relevant Marketing Programs are listed below:

E-Commerce Site Discounts. Our E-Commerce Site is only available to age-verified adults who have valid accounts on the E-Commerce Site. Any discounts and offers that we offer on the E-Commerce Site are made available to all account holders and are not conditional on the submission of additional personal information or whether such account holder has exercised any applicable privacy rights. Account holders who close and/or delete their accounts will no longer be able to access the E-Commerce Site nor be able to take advantage of any discounts or other commercial offers offered there.
Refer-an-Adult-Smoker Program. We may offer focused referral programs for adult smokers. For example, we may offer incentives to adult E-Commerce Site account holders such as discounts if an adult smoker they refer registers on the E-Commerce Site and makes a purchase. (The referred party may also receive a discount when making a purchase via your referral.) These programs are entirely voluntary and allow us to grow our business, educate qualified adults about our smokeless products, and provide additional benefits to existing customers. We do not collect personal information from you about other adults, but we may derive value if an adult party you refer ultimately engages with our Services.
Optional Programs. As further described in our Global Privacy Notice, we offer Optional Programs to eligible adult smokers to conduct market research about our customers and their use of our products. We may offer product discounts or other incentives to adult smokers who enroll in such Optional Programs.

Changes To This Notice

We may update this Notice from time to time. If we make changes, we will notify you by revising the Last Updated date above. If we make material changes, we will provide you with additional notice (such as by adding a statement to our website and mobile app or sending you a notification). We encourage you to review this Notice regularly to stay informed about our data practices and the choices available to you.