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.
1. WHAT INFORMATION DO WE COLLECT?
The categories of information we collect can include:
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 ).
2. HOW WE USE YOUR INFORMATION
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:
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.
3. THE PURPOSES FOR WHICH WE WILL USE YOUR INFORMATION
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 |
4. SHARING OF YOUR INFORMATION
We may share your personal information (for the purposes set out below above) with:
We may share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
5. RIGHTS WITH RESPECT TO YOUR INFORMATION
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.
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).
6. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
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.
7. TRANSFERRING YOUR INFORMATION OUTSIDE OF THE EEA
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.
8. HOW LONG WE RETAIN YOUR INFORMATION
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.
9. SECURITY
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.
10. CHILDREN’S PRIVACY
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.
11. LINKS TO OTHER WEB SITES AND SERVICES
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.
12. CHANGES TO OUR PRIVACY POLICY
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.
13. HOW TO CONTACT US
If you have any questions about this Privacy Policy, or privacy questions related to the ISR Programme, please contact us at dataprivacy@juul.com.