Juul Labs, INC.
Effective Date: January 1, 2020
You can also download a copy of the policy.
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.
We use different methods to collect data from and about you including through:
| Purpose/Activity | Type(s) of data (see paragraph 3 for further details) | Lawful basis for processing including basis of legitimate interest |
| To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; Asking you to leave a review or take a survey; Dealing with matters you raise with our customer service centre; To send you service communications or other communications regarding the website | Identity, Contact, Communications, App | Performance of a contract with you; Necessary to comply with a legal or regulatory obligation (including the defence of claims); Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to resolve customer issues); You have given consent |
| To use data analytics to improve our website, products/services, communications, customer relationships and experiences | Technical, Website Usage, Communications | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to improve the website experience and support personalised features, to detect and resolve technical problems and to develop our business) |
| To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you | Identity, Contact, Website Usage, Communications, Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them and to develop and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity, Contact, Technical | 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 or regulatory obligation (including the defence of claims) |
| To administer and manage your participation in a quality survey, user testing program or study. This includes sending you invitations, conducting product tests; the distribution and collection of testing materials; gathering feedback; and, managing your registration and account). | Identity, Contact | Performance of a contract with you; Necessary to comply with a legal or regulatory obligation (including the defence of claims); 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 claims and advertising substantiation (including testimonials); You have given consent |
| Provide customer services | Identity, Contact, Financial Data, Other information you may provide or we may gather (in accordance with data protection laws) | Performance of a contract with you; Necessary for our legitimate business interests (for resolving issues and complaints); Necessary to comply with a legal or regulatory obligation (including the defence of claims); You have given consent |
We strive to provide you with choices regarding certain personal data uses, particularly around how we communicate with you and advertising within our regulatory environment.
We may use your Identity, Contact, Technical and Website Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You can ask us or third parties to stop sending you permitted marketing at any time by contacting us at dataprivacy@JUUL.com. Where you opt out, this will not apply to personal data which we are still able to use, for example, to send you service messages. This includes personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How long will you use my personal data for?
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. The law allows us to extend this period in certain circumstances. Therefore, occasionally it may take us longer than a month; for example, 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
JUUL may share data internally within its group acting as either controllers or controllers to processors depending on how we determine the purpose and means of processing your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object to us processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.