Privacy Notice

POUCHBUD ("POUCHBUD," "we," "us," or "our") is committed to safeguarding your privacy. This Privacy Notice explains how and why we gather, utilize, and handle personal data when you visit or interact with our website at www.pouchbud.com (the "Website").

We encourage you to read this Privacy Notice thoroughly. Should you have any questions about our data collection or processing practices, please do not hesitate to reach out to us.

For consumers residing in states with comprehensive privacy legislation—including but not limited to California, Connecticut, Colorado, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia—please refer to Section 10 for additional disclosures.

Table of Contents

1. What personal data do we gather?
2. Where does your data come from?
3. Why do we handle personal data?
4. Age requirements and minors
5. Who do we share data with?
6. How do we safeguard your data?
7. Cookies and tracking technologies
8. Your privacy rights and options
9. Data retention periods
10. Additional notice for residents of certain U.S. states
11. Do Not Track signals
12. Cross-border data transfers
13. External links
14. How to reach us
15. Updates to this Privacy Notice

1. What personal data do we gather?

POUCHBUD may collect the following types of personally identifiable information:

• Contact details: Full name, mailing address, telephone number, and email address.
• Demographic data: Date of birth, age, and gender.
• Purchase information: Order numbers, dates, product details, quantities, pricing, shipping methods, payment methods, and purchase history.
• Payment data: Payment method, transaction timestamp, charged amount, and IP address. All card payments are handled by third-party payment processors. We do not directly collect or store payment card details entered on our Website, although we may receive associated billing information (e.g., billing address).
• Account data: Account number, username, password, and registration date.
• Communications: Notes, emails, and other correspondence related to customer support interactions.
• Survey and feedback data: Responses that may contain personal details about your preferences and product usage.
• Automatically collected data: IP address, geolocation, device details (browser type, timezone, operating system), browsing behavior, and search activity on our Website.
• Identity documents: Identification cards or similar documents used to verify your age and identity.
• Biometric data: Where you provide consent or where otherwise permitted by law, we may collect facial imagery for identity and age verification through our age-gate technology. Such biometric data may be shared with service providers enabling this verification. Where legally required, biometric data will be deleted within 1 year of your last interaction with our services.

2. Where does your data come from?

We obtain information through your direct interactions with us—for example, when you place an order, set up an account, participate in a survey, or contact us via our website form. We also use automated technologies such as cookies and web beacons to collect data. Additionally, we may supplement your information with data from third-party sources including analytics providers, advertising networks, and data aggregators.

3. Why do we handle personal data?

We collect and process your personal data for the following purposes (among others disclosed at the point of collection). Not all purposes may apply to your specific data:

• Managing your user account and profile, including account creation during checkout.
• Processing orders and purchases, including handling financial data and payment methods.
• Verifying your age prior to purchase.
• Managing customer support matters, including correcting inaccurate information and authenticating users.
• Delivering tailored offers, suggestions, and content based on your interests and purchase behavior.
• Marketing our products and services through email campaigns, custom audience advertising, and interest-based or personalized advertising, including cross-device tracking. Contact us if you wish to opt out of marketing.
• Communicating important updates, such as changes to our Terms and Conditions or this Privacy Notice.
• Conducting market research and customer database evaluation.
• Administering events, contests, and similar activities.
• Improving and developing our Website, services, products, and systems.
• Identifying security incidents and protecting against malicious, deceptive, or unlawful activity.
• Creating anonymized, aggregated datasets and performing analytics to better serve our customers and business partners.
• Sharing data with third parties as required for Website operations.
• Enforcing our agreements, policies, and legal obligations.
• Establishing, exercising, or defending legal claims, including fraud detection.

We may also use your data for other purposes clearly communicated at the time of collection or with your explicit consent.

4. Age requirements and minors

You may be asked to provide your date of birth or other age verification documentation when placing an order. This is necessary to comply with legal age restrictions on the sale of nicotine products.

We do not knowingly collect or retain personal data from anyone under the age of twenty-one. No portion of our Website is designed or intended for individuals under twenty-one years of age.

5. Who do we share data with?

We may share your data with:

• Service providers: Third parties that host our Website, assist with functionality, deliver products, process payments, or conduct data analysis on our behalf.
• Advertising partners: Third parties that may place cookies, pixels, and other tracking tools on our Website to collect data about your activities and device for the purpose of delivering personalized advertisements across their networks. This is commonly called "interest-based advertising" or "personalized advertising." See Section 8 for your opt-out options.
• Affiliated companies: Other entities within our corporate group for business and operational purposes.
• Business partners: Companies we work with that may offer products or services of interest to you.
• Legal and regulatory bodies: Where required to enforce our rights, protect property, respond to legal processes, support auditing, or comply with governance requirements.
• In connection with corporate transactions: In the event of a change of ownership or control of our company or any affiliated entity.

6. How do we safeguard your data?

We implement a range of security measures designed to prevent unauthorized access, alteration, acquisition, or misuse of your information. However, no data transmitted over the internet can be guaranteed as fully secure. It remains your responsibility to protect your login credentials.

By using our Website or sharing personal information with us, you agree that we may communicate with you electronically regarding security, privacy, and administrative matters. In the event of a security breach, we may attempt to notify you electronically through a notice on our Website, by postal mail, or via email.

7. Cookies and tracking technologies

We, along with third parties providing content, advertising, or other functionality on our Website, may use cookies, pixel tags, and similar technologies ("Technologies") to automatically gather information as you use our Website.

• Cookies: Small text files stored on your device that remember your preferences and enhance your browsing experience.
• Pixel Tags / Web Beacons: Code embedded in our Website or emails that records engagement, such as page visits, ad clicks, or email opens.

Our use of these Technologies generally falls into these categories:

• Essential: Technologies required for Website access, security, fraud prevention, and core functionality.
• Performance: Technologies used to evaluate Website performance and understand user behavior.
• Functionality: Technologies enabling enhanced features, such as recognizing returning users or remembering preferences.
• Advertising / Targeting: First-party or third-party Technologies used to deliver relevant advertisements, including cross-device tracking.

We may use the following advertising and analytics tools:

• Facebook Connect: Please review Facebook's Data Policy for details on their data usage. You can manage Facebook's ad-related use of your information through your Facebook account settings.
• Bing Ads / Microsoft Advertising: Refer to the Microsoft Privacy Statement for information on their data practices. You can manage Microsoft's ad usage through their settings.
• Google (DoubleClick): Consult Google's privacy policy. You can control Google's ad-related use of your information through their settings.
• Google Analytics: Review Google Analytics' Privacy Policy. You can opt out via the Google Analytics opt-out tool.
• Microsoft Clarity: We partner with Microsoft Clarity to understand website usage through behavioral metrics, heatmaps, and session replay. See the Microsoft Privacy Statement for details.

8. Your privacy rights and options

Depending on applicable law, you may have the following rights:

• Cookie and advertising preferences: Upon your first visit, a banner will inform you about the cookies and Technologies in use and your options. Depending on your jurisdiction, you can accept or reject certain Technologies. Please note that cookie preferences are browser- and device-specific. You can also adjust settings in your browser or use the "Your Privacy Choices" link on our Website.
• Right to Know: You may request disclosure of the personal data we have collected, the sources, the purposes, the third parties it was shared with, and the specific pieces of data collected.
• Right to Delete: You may request deletion of your personal data, subject to certain exceptions.
• Right to Correction: You may request correction of inaccurate or incomplete personal data.
• Right to Restrict or Opt Out: You may request restriction of processing involving sensitive data or profiling that produces significant legal effects.
• Right to Opt Out of Sale/Sharing: You may opt out of the sale of your personal data or the sharing of your data for targeted or cross-contextual advertising. We do not sell personal data in the traditional sense; however, we may share data with advertising partners for promotional purposes. To opt out, contact us at info@pouchbud.com or call us at the number listed below.

Global Privacy Control (GPC): You may exercise your opt-out right via a GPC signal from a supporting browser or extension. GPC preferences are linked to your browser identifier only.

The categories of data we may share for advertising purposes include: online identifiers (IP address, device identifiers), internet activity (browsing and usage data), and inferences about preferences and behaviors.

Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

How to exercise your rights: Submit a request by emailing info@pouchbud.com or calling us at the number provided in the Contact Us section. We will verify your identity by matching the details you provide against our records.

Authorized Agent: You may designate an authorized agent to submit requests on your behalf with written authorization. We may also ask you to verify your identity directly.

Appeal: You may have the right to appeal our response to your request using the same contact method.

9. Data retention periods

We retain personal data for as long as you use our Website, or as needed to fulfill the purposes for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business objectives, enforce agreements, and comply with applicable law. Below are specific retention periods by purpose:

Purpose	Data Categories	Retention Period
Order and subscription management	Communication, contact, identity, and order information	Until the order is fully processed (including delivery and payment), plus 36 months for complaint and warranty handling.
Website services	Contact, identity, order, and user-generated information	Duration of active customer relationship plus 6 months. Active = interaction within the last 12 months. Maximum 18 months without activity.
Customer support	Communication, contact, identity, and order information	Duration of active customer relationship, up to 18 months from matter completion. Social media content retained until further notice.
Marketing communications	Contact, identity, order, profile, technical, and user-generated information	Active relationship plus 12 months. Maximum 24 months without activity. Order/delivery data up to 27 months from collection.
Customer analytics	Contact, identity, order, profile, technical, and user-generated information	27 months from date of collection. Aggregated/anonymous reports retained indefinitely.
Newsletter	Contact and identity information	Active relationship plus 6 months. Maximum 18 months without activity.
Business analysis	Identity, order, profile, and user-generated information	27 months from collection. Aggregated reports retained indefinitely.
Events and contests	Communication, contact, and identity information	Duration of activity plus 26 months. Anonymized thereafter.
Market surveys	Communication, contact, and identity information	Duration of survey plus 3 months for reporting. Anonymized thereafter.
Business development	Identity, order, profile, and user-generated information	27 months from collection.
Website analytics	Identity, profile, technical, and user-generated information	See our cookie information.
Website functionality	Technical information	See our cookie information.
Partner relationship management	Identity, order, and technical information	Active relationship plus 10 years.
Technical security	Relevant data categories	Same as relevant purpose. Logs: 13 months. Backups: 13 months.
Legal claims	Data needed for the specific claim	As long as required for the claim.
Legal obligations	Data needed for the specific obligation	As required by law, plus up to 10 years. Accounting records: 7 years from fiscal year end.

10. Additional notice for residents of certain U.S. states

This section applies to residents of states with comprehensive privacy laws, including California, Connecticut, Colorado, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.

The following table describes the categories of personal data we have collected and whether we disclosed such data for business purposes or shared it for advertising in the preceding 12 months:

Category Collected	Disclosed to (Business Purposes)	Shared for (Advertising)
Identifiers (name, alias, address, unique identifiers, IP address, email, account name, etc.)	Service providers, business partners, affiliates, other users, advertising networks, analytics providers, government entities	Online identifiers shared with: advertising networks, analytics providers, social networks
Personal information categories (name, signature, address, phone, bank/credit/debit card numbers)	Service providers, business partners, affiliates, other users, advertising networks, analytics providers, government entities	N/A
Commercial information (purchase records, histories, tendencies)	Service providers, business partners, affiliates, other users, advertising networks, analytics providers, government entities	Browsing/purchase history shared with: advertising networks, analytics providers, social networks
Internet/electronic network activity (browsing history, search history, interaction data)	Service providers, business partners, affiliates, other users, advertising networks, analytics providers	Browsing/purchase history shared with: advertising networks, analytics providers, social networks
Geolocation data	Service providers, business partners, affiliates, other users, advertising networks, analytics providers	N/A
Inferences (consumer profile reflecting preferences, behavior, etc.)	Service providers, business partners, affiliates, other users, advertising networks, analytics providers	Advertising networks, analytics providers, social networks
Biometric information (facial imagery for age verification)	Service providers enabling age verification	N/A

"Sales" of personal information: We do not sell personal data in the conventional meaning. However, we may share data with advertising partners for promotional purposes, which may be considered a "sale" or "sharing" under applicable state law. You may opt out by contacting info@pouchbud.com or by using the "Your Privacy Choices" link on our Website.

Financial incentive programs: We may offer financial incentives (such as coupons, promotions, or discounts) to individuals who register an account, sign up for communications, or respond to surveys. Participation is always voluntary. The value of collected personal data varies based on the offer, purchase amounts, and future engagement.

Sensitive personal information: To the extent we collect payment data that qualifies as sensitive personal information, we process it solely to provide our products and services.

California "Shine the Light": California residents may request (once per year) information about third parties with whom we shared data for marketing purposes during the prior calendar year. Send your request to info@pouchbud.com with "California Shine the Light Privacy Request" in the subject line.

Accessible format: If you have a disability that limits your ability to access this Notice, please email info@pouchbud.com and we will provide an alternative format.

11. Do Not Track signals

Do Not Track ("DNT") is a privacy preference available in certain browsers. We do not currently respond to DNT signals; however, we honor the Global Privacy Control ("GPC") signal where required by applicable law.

12. Cross-border data transfers

Our Website is directed at and intended for residents of the United States. Data processed by us may be transferred to, processed, and stored in the United States or other countries with different data protection standards. We take appropriate measures to protect your data in accordance with applicable laws.

13. External links

Our Website may contain links to third-party websites. Those websites operate under their own privacy policies, and we are not responsible for their data practices. We recommend reviewing the privacy notice of any external site you visit.

14. How to reach us

If you have questions about this Privacy Notice, please contact us at:
Email: info@pouchbud.com
Phone: (405) 210-8879
Mail: POUCHBUD, 754 Asp Ave, Norman, OK 73069, USA

15. Updates to this Privacy Notice

POUCHBUD reserves the right to modify this Privacy Notice at any time. Changes will be published on our Website. We encourage you to review this Notice periodically.

Last updated: July 15, 2026