(Effective Date: 11/19/2021)
RESTRICTIONS ON ACCESS AND USE
Adult Audience Only. This Website is intended only for use by adults. We believe that youth should not use tobacco products. We take no actions to encourage youth tobacco use, and support programs designed to discourage and reduce youth use. In addition, our correspondence policies are designed to limit business communications to adults only. We take these issues and responsibilities very seriously. Linking to this Website from any website is expressly prohibited without permission. If you are under 21 years old or have otherwise gained access to one of this Website by providing false information such as your date of birth, leave this Website immediately.
WHY WE COLLECT
This Website is operated for the purpose of engaging tobacco and vapor rights advocacy among adult tobacco and vapor consumers, retailers, and tobacco and vapor rights advocates, including to provide information and resources to such consumers, retailers and advocates who are interested in legislative, regulatory, or other issues related to tobacco and/or vapor products and to provide a platform for discussion to such consumers, retailers and advocates. We collect information to serve these purposes, including to provide you with the information you request, or which we feel may interest you, if you have agreed to be contacted for such purposes, to administer, operate and improve this Website, to allow you to participate in interactive features of our service, when you choose to do so, to conduct analysis, to provide content that matches your preference and to administer our activation campaigns, surveys, polls, and other events related to the purpose of this Website.
WHAT WE COLLECT
We collect information about you in many ways, including directly from you, your devices and your interactions with us, whether in person, by mail or electronically, including on this Website. We may also receive information about you from service providers that provide services for us in connection with this Website as well as from service providers to whom you have provided information.
Personal Information. “Personal information” is data that can be used to uniquely identify or contact an individual, such as your name, phone or mobile number, mailing address, email address, age, social media information (e.g., ID/username, profile picture, gender, age range). There are several ways in which you may explicitly and intentionally provide us with, and consent to our collection of, personal information, including:
Examples of Information That You May Provide:
- Registering For Our Communications. When you register for our communication or sign up to receive alerts (e.g., on related issues and news) or to participate in campaigns/activities, we may collect, and associate with you, information like your name, age, email address, phone number and mailing address. We may also rely upon third-party services to review publicly available information about you to verify your age.
- Submitting Content to Us. When you use this Website, or communicate with us in other ways (e.g., email, mail, telephone, text-message, social media, mobile app or in person), we may store, process and transmit content you share or review (including things like your comments on message boards and photos you upload) and information related to them (for example, location tags in photos). This will make it easy for you to do things like share items/materials, post messages, and respond other information from us.
Examples of Information That May Be Collected Automatically:
- Location Information. Your devices may transmit general location information (e.g., region, city and state) to us. This allows us to provide you with content that may be relevant to you based on your location.
- Traffic Data. Whenever you visit or interact with this Website, we (as well as our service providers) may use assorted technologies that automatically or passively collect information about how it is accessed and used by you. We refer to this information as traffic data. Traffic data may include, but is not limited to, your IP address, device type used to access this Website (i.e., computer or mobile device), unique number assigned to identify such device, application version, click path taken through this Website and your use of features or applications on this Website. Technologies we use to collect traffic data, include, but are not limited to, cookies and beacons.
- Cookies. Cookies are pieces of information that a website stores on your computer. We may place temporary cookies or similar files on your computer or other devices used to access this Website to facilitate navigation (e.g., to streamline the login process), to personalize your experience while visiting this Website (e.g., allowing us to select content that is most likely to appeal to you based on your preferences or location), and for security purposes (e.g., to maintain security while you browse this Website and help ensure that only authorized adult tobacco or nicotine consumers are on this Website). Please refer to your browser’s help menu for more information on how to manage your cookie settings. If you disable or opt out of receiving cookies, some features and services on this Website may not work as intended and you may not have access to all of the services and features we may offer.
- Beacons. Web beacons (also known as spotlight tags, Internet tags, pixel tags and clear GIFs) are transparent images that may appear on this Website, in our emails, or elsewhere. Web beacons may collect information about your interactions with this Website and our emails, including the pages you view, the emails you open, the features you use, the links you click and other actions you take in connection with this Website or emails from us in order to deliver content that may be of the most interest to you and to improve this Website.
WHO WE MAY SHARE INFORMATION WITH
- Our Affiliates and Service Providers. We may share and disclose information among our businesses, including employees, agents and affiliates of our businesses. In addition, we may share your information with non-affiliated businesses that perform services for us. For example, among other things, we may use a service provider to correct technical problems and malfunctions on this Website and to help us provide, improve, protect, and promote this Website and services. When we contract with such service providers to help us conduct our business, we do not permit them to use or store your personal information for any purpose other than the work they are doing on our behalf or as required by law.
- Other Adult Tobacco or Nicotine Consumers. When you register for this Website you may create a user name. Your user name, alias, avatar, location, city and state of residence may be shared with other adult tobacco, nicotine, vaping, or heated tobacco consumers that access this Website. Moreover, when logged into this Website, your on-line presence within this Website may be disclosed, including if you make submissions or post comments, and we or other adults on the communications list who access this Website may be able to comment on submissions or comments you choose to share. Certain features (such as message boards) may let you make additional information available to us or other adults on the communications list who access this Website. To further protect your privacy, we encourage you not to post or otherwise disclose on this Website your phone number, physical address, e-mail address, or other personally-identifying or sensitive information.
- Legislators, Government Officials or Policymakers. This Website will use a number of activation methods and tools to meet the purpose of this Website. For example, we may use a petition as a campaigning tool. If you sign a petition using your personal information, then you should be aware that some of that information may be presented to petition targets, such as legislators, government officials and/or policymakers. Likewise, if you sign up to one of our activation tools (e.g., make a phone call or send a Tweet), then we will collect information (such as your phone number or Twitter information) related to such activity.
- Other Third-Parties. We may also share your information with non-affiliated third-parties, including, for example: (1) if we believe that there has been a violation of our policies regarding this Website; (2) if we believe that someone may be causing injury to our rights or property, or those of anyone else; (3) to respond to judicial process or to provide information to law enforcement or other governmental agencies; (4) otherwise as required by law; or (5) in the event of a liquidation, reorganization, merger, consolidation, change of control, asset or stock acquisition/disposition or other corporate combination.
HOW WE PROTECT YOUR PRIVACY
HOW YOU CAN MANAGE YOUR PRIVACY
Opting-Out. If at any time, you wish to be removed from our contact list, you can contact us by:
- Contact firstname.lastname@example.org ask to be removed from our contact list.
- Using an “unsubscribe link”. If you receive any email communication from us, you will be given the option to “unsubscribe” from receiving further email communications from us at any time.
Be sure to include any contact information that you want removed from our contact list, including physical addresses, phone numbers, and email addresses (if you use more than one email address, send your opt-out email from each of your email addresses).
We may not be able to correct or update personal information previously provided by us to third parties. Your option not to receive promotional and marketing material will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationships with us, if any (e.g., any use of our services, or responses to requests for information you pose to us either through use of this Website or by other means), and will not preclude us from accessing and viewing your personal information in the course of maintaining and improving this Website and our services.
Do Not Track Requests & Third-Party Tracking. Unless your browser settings are configured to make your online activities and publicly available information about your online activities (such as traffic data described above) invisible to usage analytics tools, your online activities within a Website are not omitted from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part. Third-parties, other than our service providers (such as our Website analytics providers), do not have authorization from us to track which websites you visited prior to and after visiting this Website. That said, we cannot control all third-party tracking and there may be some third-party tracking over time and across third-party websites that occurs without our knowledge or consent.
Making Changes to Your Personal Information. You can update certain personal information associated with you by [insert method].
How You Can Protect Your Privacy When Using This Website. You understand that personal information that you post in any public areas of this Website or social media channels can be read, collected, or used by other users of this Website, and could be used to send you unsolicited messages. You are encouraged to exercise caution when posting personal information about yourself in public areas.
How You Can Protect Yourself Against Identity Theft. If you would like to learn more about protecting against identity theft, you can visit the FTC’s website for more information on how to avoid identity theft at: https://www.consumer.ftc.gov/features/feature-0014-identity-theft.
LINKS TO THIRD-PARTY WEBSITES
From time to time, we may provide information about or links to unaffiliated third-party websites. Those websites operate independently from us (and our affiliates) and may have their own privacy statements in place which we recommend you review if you visit any linked websites. To the extent any such third-party websites you visit are not owned and operated by us or our affiliates, neither we nor our affiliates are responsible for their content or any use of those websites. The ability to access information of third-parties from this Website, or links to other websites or locations, is for your convenience and does not signify our endorsement of such third-parties, their services, other websites, products, services, locations or other content.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS & SHINE THE LIGHT
If you are a California resident, you have the right, pursuant to Section 1798.83 of the California Civil Code, to receive once a year, free of charge: (1) information identifying each third-party company to whom we may have disclosed, within the past year, personal information pertaining to you for that company’s direct marketing purposes; and (2) a description of the categories of personal information disclosed to that third-party company in the immediately preceding calendar year. If you are a California resident and would like to make this request, please call 1-800-665-6381. In addition, please refer to “Who We May Share Information With” above to see our practices related to our affiliates.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CCPA RIGHTS
If you are a California resident, you have certain rights, pursuant to the California Consumer Privacy Act of 2018 (or “CCPA”). These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.
|Right to Know||As a California resident, you have the right to request that we disclose what personal information we collect, use, disclose and/or sell. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, that service provider will not retain such information provided for verification purposes.|
|Right to Request Deletion||As a California resident, you have a right to request the deletion of your personal information collected or maintained by us. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, that service provider will not retain such information provided for verification purposes.|
|Right to Non-Discrimination||As a California resident, you have a right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights.|
|Authorized Agent||As a California resident, you can exercise your CCPA rights or you can designate an authorized agent to make a request on your behalf. We may require that you provide the authorized agent written permission to submit a request on your behalf and that the authorized agent verifies their own identity directly with us.|
|Category of personal information||Sources of personal information||Business or commercial purpose for which it was collected||Categories of third-parties with whom the business shares personal information|
|Identifiers (such as name, date of birth, telephone number, mailing address, email address, internet protocol address, and unique number assigned to identify the device used to access this Website)||Directly from you; via our service providers||For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, processing payments, verifying information, providing advertising or marketing services and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes||N/A|
|Categories of personal information outlined in Section 1798.80(e) (such as name, address, and telephone number)||Directly from you; via our service providers||For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying information, providing advertising or marketing services and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes||N/A|
|Characteristics of certain protected classifications under California or federal law (such as age (40 years or older) and sex (including gender))||Directly from you; via our service providers||For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, verifying information, providing advertising or marketing services and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes||N/A|
|Commercial information, including products or services purchases, obtained, or considered, or other purchasing or consuming histories or tendencies||Directly from you; via our service providers||For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying information, providing advertising or marketing services and providing analytic services; commercial purposes||N/A|
|Geolocation data||Directly from you; via our service providers||For our operational purposes; performing services on behalf of the business including providing advertising or marketing services and providing analytic services; commercial purposes||N/A|
|Inferences drawn from any personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior and attitudes||Derived from information we received directly from you and via our service providers||For our operational purposes; performing services including maintaining or servicing accounts and providing advertising or marketing services and providing analytic services; commercial purposes||N/A|
If you are a California resident and would like to submit a verifiable consumer request, you can do so using any of the following designated request methods:
- To submit a request on behalf of yourself, please complete a webform using this link CCPA_Rights_Request;
- To submit a request for a California resident as an Authorized Agent, please complete a webform using this link CCPA_Agent_Request;
- For information regarding submitting a Household request, please visit this link.
Alternatively, you may also call our toll-free number at 1-877-881-0861 to submit a request. Please follow the voice prompts and speak slowly and clearly so we may complete your request.
We may ask for certain information to verify a request in accordance with applicable law.
We did not disclose or sell any personal information to third parties for their business or commercial purposes during the last 12 months. We do not knowingly collect any personal information from anyone under 21 years of age.