JLI Science Privacy Policy

Last Modified: September 30, 2019

JUUL Labs, Inc.
560 20th St.,
San Francisco, CA 94107

JUUL Labs, Inc. (“JUUL Labs,” “we,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, stored and disclosed by JUUL Labs. This Privacy Policy applies to our website, http://jliscience.com, any other website that links to this Policy, as well as any other data we collect in relation to Investigator Sponsored Research (“ISR Programme”), 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

This website and the ISR Programme are not intended for children and we do not knowingly collect data relating to children. For more information, see paragraph 10.


The categories of information we collect can include:

  • Information you provide to us directly. We may collect personal information directly including: your name, credentials, organization, phone number and email address, when you submit a research proposal; your written agreement, when you provide this to participate as an investigator in the ISR Programme; your research study, when you provide or communicate with us about this; your contact details and other information you provide as a sponsor or funder of ISR research or if you are a member of an institution participating in ISR research; and, other personal data which you provide when communicating with us in relation to the ISR Programme. We may also collect any other communications between you and JUUL Labs (or our other JUUL companies). We use this information to run and manage the ISR Programme, as well as to communicate directly with you. A full list of our data uses is provided below at paragraph 2.
  • Information collected automatically. We, and our third-party partners, automatically collect certain types of usage information when you visit this website, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp (a unique ID that allows us to uniquely identify your browser, mobile device, or your account), and other such information. We also collect information about the way you use our website, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the website, whether you open emails or click the links contained in emails, whether you access the website from multiple devices, and other actions you take on the website. When you access our website from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the website and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. 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.

We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the website; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our website; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our website. We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the website, as some features and services on our website may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (“LSOs“) such as Flash objects and HTML5. You can learn more about Flash objects—including how to manage privacy and storage settings for Flash cookies—on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.

Where we need to collect personal data by law, or under the terms of an agreement 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 services relating to ).


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:

  • Where we need to perform the agreement 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 ISR Programme;
  • 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;
  • Where we need to comply with a legal or regulatory obligation.

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 permitted 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.


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 ISR Programme and account creation, including validation of your selection and qualification documentation by JUUL Labs Medical Affairs Staff Performance of a contract with you, for our legitimate interests (to manage and administer the ISR Programme)
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 ISR Programme, effectively provide services and keep our records updated)
To administer and manage your participation in the ISR Programme (including submission and approval of study proposals, managing proposals (including sharing proposals with JUUL’s formalised disciplinary team) managing and administering ISR 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 ISR Programme) with your Consent
To facilitate and publish independent sponsored research studies via the ISR Programme, including on the website, and to make the research available to key JUUL stakeholders, the JUUL Scientific Community, patients/research subjects and others Performance of a contract with you; Necessary to comply with a legal or regulatory obligation; Necessary for our legitimate interests (in arranging and publishing clinical and/or perceptual, behavioural, and observational studies)
To arrange and manage investigator sponsorship with a sponsor, affiliated study sponsor or other funder Performance of a contract with you; Necessary to comply with a legal or regulatory obligation; Necessary for our legitimate interests (in funding ISR proposals and research)
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 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



We may share your personal information (for the purposes set out below above) with:

  • 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;
  • Third-party vendors and other service providers 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 tax and accounting services, research and development services or providing analytic services;
  • Third-party independent scientific research sponsors, affiliated study sponsors or other funders;
  • JUUL Labs’ Scientific Community and patients may receive information about independent scientific research we support and the institutions and investigations which JUUL Labs supports;
  • Other parties in connection with a company transaction, such as a merger, 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;
  • Regulators, where they are involved in study proposals or research; and,
  • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with laws or regulations and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our website or services; and/or (c) to exercise 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.


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.

  • 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 dataprivacy@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. For example, 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.

You can stop receiving email communications from us by clicking on the link provided in such communications. We make every effort to promptly process all requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the website, technical and security notices).


We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third party online advertising networks, social media companies and other third-party services, to collect, information about your use of our websites over time so that they may play or display ads on our websites, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. 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. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again. You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).

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 and to tailor our advertisements and content to you. 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 here https://tools.google.com/dlpage/gaoptout/.We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the website. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.


Your information collected through our website or the ISR Programme may be stored and processed in the United States or any other country in which JUUL Labs or its parent, subsidiaries, 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.

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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.


We will retain your personal information only for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of meeting legal, regulatory, reporting and accounting obligations, and for the purposes described in this Privacy Policy.

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 unauthorized 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.

In some circumstances you can ask us to delete your data: please see “Rights with respect to your information” at paragraph 5 above for further information.

In some circumstances we may anonymize and/or aggregate personal information (so it can no longer be associated with you) and store it in order to analyze aggregate metrics and trends, in which case we may use this information indefinitely without further notice to you.

Please note: written ISR agreements are filed and stored in the centralized JUUL Labs Contracts repository.


We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website and the ISR Programme. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. Any transmission of information is at your own risk. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.


JUUL Labs does not knowingly collect or solicit any information from anyone under the age of 13 on this website or via the ISR Programme. 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 dataprivacy@juul.com.


The website may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.


We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy in a material manner, we will upload a new version to the website and update the ‘last modified’ date at the top of this page.


If you have any questions about this Privacy Policy, or privacy questions related to the ISR Programme, please contact us at dataprivacy@juul.com.