Privacy Policy

1. Introduction

This Privacy Policy explains how Afton Biotech LLC ("Peelz," "we," "us," or "our") collects, uses, and shares information when you visit www.peelznicotine.com (the "Site"), purchase Peelz Nicotine Strips, complete our personalized plan questionnaire, or otherwise interact with us.

By using the Site, you agree to the practices described here. If you do not agree, please do not use the Site or our services.

2. Information we collect

Information you provide

• Account & contact information: name, email address, phone number, shipping and billing address.
• Order information: products purchased, payment method (processed by our payment provider — we do not store full card numbers), order history.
• Personalized plan information: nicotine usage history, time-to-first-cigarette, daily caffeine intake, age range, pre-existing health conditions, medications, pregnancy/breastfeeding status, and other answers you provide in our plan questionnaire.
• Consent forms & signatures: when you complete the informed-consent form.
• Support communications: messages, calls, and emails you send us.

Information collected automatically

• Device & usage data: IP address, browser type, device type, operating system, referring URL, pages viewed, and time on page. [PLACEHOLDER: confirm scope of analytics actually deployed]
• Local storage: we store an age-verification flag (peelz_age) in your browser's localStorage so the 21+ confirmation only appears once.
• Cookies: see Section 5.

Information from third parties

[PLACEHOLDER: list third-party sources, e.g., Shopify order data, payment processor, shipping carrier, analytics provider, ad networks. Remove if none.]

3. How we use information

• Process and fulfill orders, including shipping and customer service.
• Generate your personalized step-down plan and product recommendations.
• Communicate with you about orders, your plan, and product safety.
• Send marketing communications where you have opted in (you can opt out at any time).
• Operate, maintain, and improve the Site and our services.
• Detect, investigate, and prevent fraud, abuse, and security incidents.
• Comply with legal obligations, including age-verification and recordkeeping requirements applicable to nicotine products.

Legal bases (for users in the EEA/UK): contract performance, legitimate interests, consent, and compliance with legal obligations. [PLACEHOLDER: confirm which apply to your operations]

4. When we share information

We do not sell your personal information. We share information only as described below:

• Service providers who process data on our behalf (e.g., payment processor, shipping carrier, email/SMS provider, analytics, customer-support tooling, hosting). [PLACEHOLDER: list specific subprocessors]
• Healthcare partners only with your consent, where you have asked us to coordinate with a clinician or surgical team.
• Legal & safety: to comply with law, respond to lawful requests, protect rights and safety, or in connection with a corporate transaction (merger, acquisition, financing).

Sale or sharing for cross-context advertising: [PLACEHOLDER: state Yes or No. If Yes, provide CCPA/CPRA "Do Not Sell or Share My Personal Information" link and disclosures.]

5. Cookies & local storage

We use cookies and similar technologies to operate the Site, remember preferences, and (where applicable) measure usage. The age-gate flag is stored in your browser's localStorage and is not sent to our servers.

[PLACEHOLDER: list each cookie/category — strictly necessary, functional, analytics, advertising — with purpose, provider, and retention. Add cookie banner / consent management for EU/UK visitors if applicable.]

You can control cookies through your browser settings. Blocking some cookies may break parts of the Site.

6. Health information

Our personalized plan questionnaire collects information about nicotine use, medications, pregnancy status, and health conditions. We treat this information with heightened care.

[PLACEHOLDER: state whether Peelz is acting as a HIPAA "covered entity" or "business associate," whether the questionnaire is considered medical advice, and any clinician partnerships involved. Have an attorney confirm HIPAA, FTC Health Breach Notification Rule, and state health-data law applicability before launch.]

7. Data retention

We retain personal information for as long as needed to provide our services, comply with legal obligations (including age-verification and tax records), resolve disputes, and enforce our agreements. [PLACEHOLDER: insert specific retention periods per data category]

8. Security

We use administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is fully secure, and we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately.

9. Your rights

Depending on where you live, you may have the right to:

• Access, correct, or delete personal information we hold about you.
• Receive a copy of your information in a portable format.
• Object to or restrict certain processing.
• Withdraw consent where we rely on it.
• Opt out of the "sale" or "sharing" of personal information (CA/CO/CT/VA and other states).
• Lodge a complaint with a data protection authority (EEA/UK).

To exercise these rights, contact us at [privacy@peelznicotine.com — confirm address]. We will respond within the period required by applicable law.

10. Children's privacy

Peelz is intended for adults 21 and older. We do not knowingly collect personal information from anyone under 21. If you believe a minor has provided us with personal information, please contact us so we can delete it.

11. International users

The Site is operated from the United States. If you access it from outside the U.S., your information will be transferred to and processed in the U.S. and other countries with different data protection laws than your home jurisdiction. [PLACEHOLDER: add Standard Contractual Clauses / UK IDTA language if you serve EEA/UK users]

12. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent revision. Material changes will be notified through the Site or by email where appropriate.

13. Contact us

Questions or requests? Reach us at:

Afton Biotech LLC
2150 Wise St #4263
Charlottesville, VA 22905, USA
Email: [privacy@peelznicotine.com]
Phone: (800) 555-2045