JUUL LABS, INC.

PRIVACY POLICY

Effective Date: 18-07-2019

Welcome to www.JUUL.id,operated and managed by PT Asia Anugrah Teknologi Indonesia, the online retailer ("Exclusive Online Retailer") for PT Jagad Utama Lestari (“Distributor”), the exclusive Indonesian distributor of the products of JUUL Labs, Inc (“JUUL Labs”). The Distributor and Exclusive Online Retailer belong to the Erajaya group of companies. The terms "we" or "us" refers to the Exclusive Online Retailer and JUUL Labs.

This privacy policy addresses how information is collected, stored, and utilized through (1) the www.JUUL.id website (“Website”), (2) any customer support we may offer via JUUL Labs Customer Care phone and email support ("Customer Care"), (3) any marketing activities we carry out where you provide personal information, and (4) any mobile or web-based application we may offer from time to time which is linked to this Policy (the “App”) (collectively, the “Services”).

In Indonesia, the Exclusive Online Retailer collects your data and is responsible for the handling and processing of your data. In providing Services, JUUL Labs or the Distributor may support the Exclusive Online Retailer and handle your data consistent with this policy.

By accessing or using our Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

The Exclusive Online Retailer reserves the right to change this Privacy Policy from time to time. See the section captioned “Changes to this Privacy Policy” below.

1. INFORMATION THAT YOU PROVIDE TO US

The Exclusive Online Retailer may collect personal information that you provide to the Exclusive Online Retailer directly, such as your name, phone number, location, payment information, and e-mail address when you when you register on the Website, purchase a product, sign up for our Newsletter mailing list, or otherwise communicate with us (e.g., via customer service). Account creation is required when purchasing products from the Website.

The Exclusive Online Retailer may also collect any communications between you and JUUL Labs and any other information you provide to JUUL Labs (as applicable). For example, in providing the Customer Care, the Exclusive Online Retailer may be supported by JUUL Labs which will collect information on behalf of the Exclusive Online Retailer. Customer Care will handle any issue relevant to all online or offline customers. To ensure provision of seamless Customer Care service, any information collected through Customer Care may be shared among, and used by, the Exclusive Online Retailer, the Distributor, JUUL Labs, and/or other authorised JUUL retailers (as applicable).

If you download and use the App to access the Service, the App does not require you to enter any personally identifiable information, though you may voluntarily provide information to us through the App, for example, when you contact us through the App’s customer service link and provide to us your name, email address and any information you choose to include in the text of your message.

At this moment, the information will be mainly collected via Customer Care, however, in the near future the above will be applicable when the Website function has been developed."

The Exclusive Online Retailer uses this information to operate, maintain, and provide to you the features and functionality of the Website, as well as to communicate directly with you, such as to send you email messages. The Exclusive Online Retailer 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). JUUL Labs, in support of the Exclusive Online Retailer, will use the information for the same purpose.

Information automatically collected:

We and our third party partners, automatically collect certain types of usage information when you visit the Website, use our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technologies (collectively, “tracking technologies”). For example, we may collect information such as your domain name, browser type, operating system, IP address, web pages viewed while visiting our site, links clicked, length of time spent on our Service, and reference website from which you accessed the Website. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Website and to understand more about the demographics of our users. In gathering this information we are able to enhance your experience when visiting our Website (including keeping your preferences and items placed in your shopping cart between visits) and to provide custom, personalized content and information, including targeted content and advertising. These cookies do not contain or track sensitive information such as your payment information. You may set your browser to not accept cookies; however, some features of the Websites may not function properly without the use of cookies. 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.

If you download and use the App to access the Service, we automatically collect certain types of information about your device and usage in several ways. When you download and use the App, we will automatically receive certain information, about which JUUL Labs products that are connected to the App, your mobile device and your usage of the App, such as the device operating system and version and information regarding your use of the App, such as the time spent using the App, which features of the App you access and use, and error messages but not specific identifying information about you. We may modify the information that we receive from the App at any time and will provide you notice of such changes by alerting you of a change to the Privacy Policy.

The App may store information regarding usage of a compatible JUUL Labs device that you have linked to the App when the App is running or when a compatible JUUL Labs product is available to pair with the App. Such information may include identification and paring information to connect with a JUUL Labs product, log files, modes, settings, durations, error rates, and other information that may be useful to enhance the connectivity between a compatible JUUL Labs product and the APP. We do not link this Device Usage information to your personal information in our systems and this information is transmitted in an anonymous form and in an encrypted manner. If you do not opt-in to the Usage Recording Feature, the App will not collect any device usage information. If you do opt-in and choose to save certain settings or save user profiles in a durable, continuing manner for future sessions regardless of JUUL Labs product, this information may be retained by JUUL Labs.

2. USE AND SHARING OF INFORMATION COLLECTED

We utilize information that is collected in various ways. Any information received from authorised JUUL retailers will be used based on the terms of this Privacy Policy.

Information collected by us helps our efforts to advance the Exclusive Online Retailer's customers’ and visitors’ online experience when visiting our Service. This ranges from accessibility, improving content, customer service, shopping checkout experience and overall Service satisfaction. We also use information we collect to assist with product development efforts, response to mandated legal notices, process purchases on the Websites, to provide you with products or services you request from us, to improve your overall experience with the Services, for internal analytics purposes, to troubleshoot technical difficulties and errors, to notify you about changes to our Services, and in any other way we may describe to you at the time you provide the information. We may share your personal information with:

  • Third-party vendors, service providers, contractors and agents that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving advertisements, providing mailing services, providing financial services, web hosting, or providing analytic services. This sharing is only done so when those entities are performing functions solely on our behalf and they are not permitted to store such information except as needed to perform our work or as required by law;
  • When you post content to any public area of our externally facing platforms, including social media pages or blog, this information may be visible to the public and we may publish this information on our website and social media pages along with some of your personal information such as your first name, last initial, and state of residence;
  • With your consent, to third parties who may send you offers and information about products and services we think you may enjoy; 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 will use your personal information in the same way as we can under this Privacy Policy;
  • Other parties in connection with a company transaction, such as a merger, corporate restructuring, 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; and
  • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Services; and/or (c) to exercise, investigate, or protect the rights, property, or personal safety of JUUL Labs, our visitors, or others.
  • We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

PLEASE NOTE: The products sold on this website are highly regulated by various governing agencies. It may become necessary to share the information that we collect with such agencies to comply with laws, a judicial proceeding, court order, or other legal requests.

We also may disclose information that has been collected where we believe it is necessary to investigate, prevent, or take action regarding underage use or purchase of JUUL Products, illegal activities, suspected fraud and/or counterfeit, situations involving potential threats to the safety of any person, violations of our Terms of Service or Privacy Policy, or as evidence in litigation in which JUUL Labs is involved.

3. AGE VERIFICATION

The products that the Exclusive Online Retailer sells on the Website are highly regulated and age-restricted. We are required and committed to preventing sales to anyone under the legal purchasing age. We will only send you marketing materials and information that encourage or facilitate a purchase of our products after you have certified that 1) you are a of legal purchasing age for the product you wish to purchase; 2) that you wish to be added to our mailing list for the purpose of receiving transactional offers and advertising from a tobacco-regulated company; and 3) that you understand that providing false information may constitute a violation of the law.

Before you can make a purchase from a product specific newsletter mailing list, we will verify your age through a non-affiliated third party company to perform an age and identify verification check for adherence to this requirement. We utilize these trusted verification services to verify the information that you provide and ensure that you qualify to access and purchase products from the Website. This process has been developed with the customer’s privacy in mind with detailed information neither shared nor accessible.

In some cases, we might not be able to verify your age and/or identity through their verification service. If you are unable to verify your age with the requested information, you will be requested to upload a copy of your government ID that our team can manually verify your date of birth. Photo ID’s are uploaded to our third party partner’s secure database and we simply process the result that they provide – we do not receive a file with your ID to be stored on our servers or database.

4. THIRD PARTY TRACKING AND ONLINE ADVERTISING

We may share, or we may permit third party online advertising networks and other third party services, to collect, information about your use of our Service over time so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or apps. Additionally, the Website utilizes third party sites to provide content to the Exclusive Online Retailer's customers such as social media features. These third party sites may set cookies on your browser and/or obtain your IP address. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the Website, and other information. This information is used to display targeted ads on or through our Service or on other websites or apps, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. We do not permit third parties to collect your identifiable information from the Website unless you provide it to them directly.

Information Collected Via Technology
As you use the Services, certain information may also be passively collected and stored on our or our service providers’ server logs, including your Internet protocol address, browser type, and operating system. We also use Cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed, or on which of the advertisements displayed on Services you clicked. This type of information is collected to make the Services more useful to you and to tailor the experience to meet your special interests and needs.

An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. For example, we, or our service providers, may track your IP Address when you access the Services to assist with ad targeting.

“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience with JUUL Labs. Persistent Cookies can be removed by following your Internet browser help file directions. In order to use the Services, your web browser must accept Cookies. If you choose to disable Cookies, some aspects of JUUL Labs may not work properly, and you will not be able to receive our services.

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, and you may also adjust your ad preferences through your Facebook settings.

5. RIGHTS WITH RESPECT TO YOUR DATA

Modifying or deleting your information. If you have any questions about reviewing, modifying, correcting, or deleting your information, or if you want to remove your name or comments from our Website or publicly displayed content, you can contact the Exclusive Online Retailer via JUUL Labs at dataprivacy@juul.com. JUUL Labs will bring your question to the attention of the Exclusive Online Retailer. We may not be able to modify or delete your information in all circumstances.

Opt-out of App’s Usage Recording Feature. You may turn off the App’s Usage Recording Feature at time of download, or you may delete the App from your device.

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

6. CHILDREN’S PRIVACY

Our Service is not intended for individuals under the age of 18 and for warranty, the age of 18. We do not knowingly collect or solicit any information from anyone under the age of 18 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 18, please contact the Exclusive Online Retailer via JUUL Labs at dataprivacy@juul.com. JUUL Labs will bring your enquiry to the Exclusive Online Retailer's attention. Protecting the privacy of children and youth is very important to us. Thus, if we obtain actual knowledge that a user is under 18, we will take steps to remove that user’s Personal Information from our databases. We recommend that anyone under the age obtain their parent’s permission before submitting information over the internet.

7. USERS OUTSIDE OF THE U.S.

Your information collected through our website may be stored and processed in the United States or any other country in which JUUL Labs or its 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, and you consent to the transfer of information to the U.S. or any other country in which JUUL Labs or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

8. THIRD PARTY WEBSITES

Our Service may contains links to websites operated by third parties. This Privacy Policy does not apply to these third party website or services. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms & conditions and that we do not accept any responsibility or liability for their policies. Links should be clicked at your own risk, and it is your sole responsibility to review the applicable privacy policy and terms and conditions of any third party website accessed.

9. SECURITY

We take the security of your information extremely seriously and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website. Our Services support the industry standard Secure Socket Layer (SSL) encryption which is applied to all data transmitted so it cannot be read by others. In addition, if you are using a shared computer to access the Website, we recommend that you log out of your account before ending your browser session. This will also ensure that your account will not be used by anyone other than yourself. Unfortunately, the transmission of information online is not completely secure. Although we do our best to protect all information collected through the Service, we cannot guarantee the security of your information collected and/or transmitted through the Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

10. PARTNER TECHNOLOGY PRIVACY POLICY

The Exclusive Online Retailer collects information on in the form of the content that you submit during your use of the Services, such as photos, comments, ratings and other information you choose to submit. The Exclusive Online Retailer may also collect information about you and your friends, from any social network you may have connected from, in order to provide you with a more personalized experience. For instance, the Exclusive Online Retailer may collect your user ID or profile information that you have permitted to be displayed through the Services in order to display you as a friend or in association with your profile and collections. When you order the products or services, you will need to submit your credit card or other payment information so that our service providers can process your payment for those products and services. If you choose to sign up to receive information about products or services that may be of interest to you, the Exclusive Online Retailer will collect your email address and all related information. Additionally, the Exclusive Online Retailer collect any information that you voluntarily enter, including Personal Information, into any postings, comments, or forums within the JUUL Labs community. For each of these Personal Information collections (or any below), the Exclusive Online Retailer will ask for your consent and provide you with clarity before making any such collections. Additionally, you will have the option to opt out of any of these collections at any time and the Exclusive Online Retailer will stop collecting such data from you. This collected information may be shared with JUUL Labs for the purpose to support the Exclusive Online Retailer maintains its customers' database. The Exclusive Online Retailer collects the above information on behalf of the Distributor.

Personal Information from Other Sources
We may receive Personal Information about you from other sources with which you have registered, companies who we have partnered with (collectively, “Partners”) or other third parties. We may associate this information with the other Personal Information we have collected about you.

E-mail and E-mail Addresses
If you send an e-mail to the Exclusive Online Retailer, or fill out the “Feedback” form through the Services, the Exclusive Online Retailer will collect your e-mail address and the full content of your e-mail, including attached files, and other information you provide. The Exclusive Online Retailer may use and display your full name and email address when you send an email notification to a friend through the Services or the social network from which you have connected to JUUL Labs (such as in an invitation, or when sharing your content). Additionally, the Exclusive Online Retailer may use your email address to contact you on behalf of your friends (such as when someone sends you a personal message) or notifications from a social network or other website with whom you have registered to receive such notifications. The Exclusive Online Retailer may use this e-mail address to contact you, for things such as notifications of limited edition shop sales and other related information. You may indicate your preference to stop receiving further promotional communications as further detailed below. This collected information may be shared to JUUL Labs for the same purpose. JUUL Labs will only contact you on behalf of the Exclusive Online Retailer. The Exclusive Online Retailer collects the above information on behalf of the Distributor.

You understand that when you use the Services, certain information you post or provide, such as your name, profile, comments, posts and ratings, may be shared with other users and posted on publicly available portions of JUUL Labs, including without limitation, chatrooms, bulletin and message boards, along with other public forums. Please keep in mind that if you choose to disclose Personal Information when posting comments or other information or content through the Services, this information may become publicly available and may be collected and used by others, including people outside the JUUL Labs community. We will not have any obligations with respect to any information that you post to parts of the Services available to others, and recommend that you use caution when giving out personal information to others in public forums online or otherwise. We also share the information you publish with other third parties.

11. CHANGES TO THIS PRIVACY POLICY

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the Privacy Policy in a material manner we will let you know and update date at the top of this page. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.

12. CONTACT US

If you have any questions about this Privacy Policy, please contact the Exclusive Online Retailer via JUUL Labs at dataprivacy@juul.com. JUUL Labs will raise your question with the Exclusive Online Retailer.