Privacy Policy

Effective Date: January 1, 2025

Last Updated: December 2, 2025

Funnels LLC ("Funnels," "we," "us," or "our") values and respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit or use our website at www.buyfunnels.com (the "Site") and purchase our tobacco products.

By accessing or using our Site, you consent to the collection, use, and sharing of your personal information as described in this Privacy Policy. If you do not agree with our practices, please do not use our Site.

Age Verification and Access Restrictions

You must be at least 21 years of age to access this Site and purchase tobacco products. By accessing or using our Site, you certify that you are 21 years of age or older and an adult tobacco consumer.

We use third-party age verification services (AgeChecker.Net) to independently verify your age before granting access to the Site and e-commerce features. Age verification is required at the time of purchase and may be required again at the time of delivery in accordance with federal and state law.

1. Personal Information We Collect

We collect the following categories of personal information to process orders, verify age, comply with legal requirements, and improve your experience. In compliance with the Maryland Online Data Privacy Act (MODPA), we collect only the minimum information necessary to provide our products and services.

Identification Information

Full legal name

Date of birth

Government-issued ID number (driver's license or state ID) for age verification

Why we collect this: Federal law (Tobacco 21 and PACT Act) requires us to verify you are 21+ before processing tobacco sales.

Contact Information

Email address

Phone number (for SMS shipping notifications and customer service)

Shipping address

Billing address

Why we collect this: Email and shipping address are required to process and deliver your order. Phone number is optional but recommended to receive SMS updates about your order status, delivery times, and customer support communications. You may opt out of SMS at any time by texting STOP.

Account Information

Username and password

Order history

Subscription preferences and settings

Saved payment methods (tokenized, not stored by us)

Why we collect this: Required to manage your account and process recurring subscriptions.

Payment Information

Credit/debit card information (processed and stored by our payment processor, Stripe) Billing address

Why we collect this: Required to process payments. Your card information is NOT stored by Funnels—it is securely processed and stored by Stripe, which is PCI-DSS compliant.

Geolocation and Compliance Data

IP address

Shipping destination (to verify legal sales jurisdiction)

Why we collect this: Federal law requires us to verify that your location allows tobacco sales. We use this to comply with state and local tobacco sales restrictions.

Transaction Information

Purchase history

Product preferences

Subscription tier and frequency

Why we collect this: Required to fulfill your orders and process refunds/disputes.

Communications

Customer service inquiries

Survey responses

Product reviews and feedback

Email and SMS communications (if you opt in)

Why we collect this: To respond to your questions and improve our services.

Technical and Usage Data

Browser type and version

Device information

Pages visited and time spent on Site

Referral source

Cookies and similar tracking technologies

Why we collect this: To understand how you use our Site and improve its functionality and security.

2. How We Collect Your Information

We collect personal information when you:

Create an account or register on our Site

Make a purchase or subscribe to our products

Verify your age through our third-party verification service

Contact customer support or submit inquiries

Sign up for our mailing list or promotional communications

Participate in surveys, reviews, or feedback forms

Opt in to SMS communications

Browse our Site (through cookies and tracking technologies)

3. How We Use Your Information

We use your personal information for the following purposes:

Legal Compliance and Age Verification

Verify that you are 21 years of age or older

Comply with federal, state, and local tobacco sales laws

Maintain records required by the PACT Act and state tobacco regulations

Report sales data to regulatory authorities as required by law

Order Processing and Fulfillment

Process and fulfill your orders

Manage subscription billing and renewals

Arrange shipping and delivery via FedEx or UPS with adult signature confirmation Send order confirmations, shipping notifications, and delivery updates

Handle returns, refunds, and damaged product claims

Customer Service and Communication

Respond to your inquiries and support requests

Provide updates about your account or orders

Send transactional emails (order confirmations, password resets, etc.)

Send SMS notifications about order status and delivery (if you opted in)

Marketing and Promotions (with your consent)

Send promotional emails, newsletters, and special offers

Notify you of new products or subscription options

Note: We do NOT use your purchase history to create targeted profiles or send personalized ads without your consent. You may receive product announcements based on your purchase of tobacco, but you can unsubscribe at any time.

Site Improvement and Analytics

Analyze Site usage and customer behavior

Improve Site functionality and user experience

Conduct research and analytics

Prevent fraud and ensure Site security

Legal and Safety

Enforce our Terms and Conditions

Protect against fraud, abuse, and illegal activity

Respond to legal requests and comply with applicable laws

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our Site. Cookies are small data files stored on your device that help us:

Keep you logged in to your account

Remember items in your shopping cart

Save your preferences and settings

Analyze Site traffic and usage patterns

Detect and prevent fraud

Types of Cookies We Use

Essential Cookies: Required for Site functionality (account login, checkout process, age verification) Performance Cookies: Help us understand how visitors use our Site (Google Analytics) Functional Cookies: Remember your preferences and settings

Advertising Cookies: Deliver relevant ads and measure campaign effectiveness

Managing Cookies

You can control cookie preferences through your browser settings. Note that disabling cookies may limit your ability to use certain Site features, including account login and checkout.

To opt out of interest-based advertising:

Digital Advertising Alliance: www.aboutads.info/choices

Network Advertising Initiative: www.networkadvertising.org/choices

5. How We Share Your Information

We do not sell your personal information to third parties. We may share your information with the following categories of recipients:

Service Providers

Age Verification: AgeChecker.Net (to verify you are 21+)

Payment Processing: Stripe (to process payments securely)

Subscription Management: Recharge (to manage recurring subscriptions)

Shipping Carriers: FedEx and UPS (to deliver orders with adult signature confirmation) Email Services: Marketing and transactional email providers (if applicable)

Analytics: Google Analytics and similar services

All service providers have executed data processing agreements with us and are required to protect your personal information to the same extent we do.

Legal and Regulatory Authorities

Federal, state, and local government agencies (to comply with tobacco sales reporting requirements, PACT

Act, and other legal obligations)

Law enforcement (in response to subpoenas, court orders, or legal processes)

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity

With Your Consent

Any other parties with your explicit consent

6. Third-Party Websites and Links

Our Site may contain links to third-party websites, including social media platforms and partner sites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

7. Data Security

We implement industry-standard security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of sensitive data (SSL/TLS) in transit

Secure payment processing (PCI-DSS compliant via Stripe)

Restricted access to personal information (only authorized employees have access)

Regular security audits and monitoring

Secure backup procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a security breach that compromises your personal information, we will notify you via email at the address on file within 30 days of discovery, as required by Maryland law.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal and regulatory obligations.

Specific Retention Periods

Age Verification Records: Minimum 4 years (FDA Tobacco 21 and PACT Act requirement) Tobacco Sales Transaction Records: 3 years (for dispute resolution and tax compliance)

Account Data (after account deletion): Anonymized within 90 days, unless retention is required by law Marketing/Email Subscription Data: Until you unsubscribe or request deletion

Analytics Data: Generally deleted after 26 months (standard Google Analytics retention) Payment Information: Handled by Stripe per their retention policy; we do not store full card numbers

If you close your account, we will delete or anonymize your personal information within 90 days, except where retention is required by law (including age verification records required by the FDA).

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information. To exercise any of these rights, contact us as described in the "How to Exercise Your Rights" section below.

Access and Portability

You may request a copy of the personal information we hold about you in a portable format.

Correction

You may update or correct inaccurate or incomplete information in your account.

Deletion

You may request deletion of your personal information, subject to legal retention requirements (e.g., age verification records must be kept for 4 years per FDA law).

Opt-Out of Marketing

Unsubscribe from marketing emails: Click the unsubscribe link in any email

Opt out of SMS messages: Text STOP to any message we send

Disable cookies: Through your browser settings

Do Not Sell My Personal Information

We do not sell personal information to third parties. If this practice changes in the future, we will provide an opt-out mechanism and prior notice.

10. How to Exercise Your Rights

To exercise any privacy rights, please contact us using one of the following methods:

Email: [email protected]

Subject Line: "Privacy Rights Request – [Access/Delete/Correct]"

Or use our online form: [Privacy Rights Request Form] (link to be added to website)

Response Timeline

We will acknowledge your request within 10 business days

We will respond fully to your request within 30 days (as required by MODPA)

For deletion requests, we will delete your data within 45 days unless retention is required by law

No Discrimination

You will not be charged different prices, offered different services, or treated differently for exercising your privacy rights.

11. Maryland-Specific Disclosures (MODPA)

Effective Date: April 1, 2026

If you are a Maryland resident, you have additional rights under the Maryland Online Data Privacy Act (MODPA).

Data Minimization Commitment

In compliance with MODPA, we collect only the minimum personal information necessary to process your tobacco order, verify your age, and comply with federal and state law. We do not collect demographic information, health data, or other sensitive personal information beyond what is required.

Consumer Rights

You have the right to:

Access: Request a copy of the personal information we hold about you

Correct: Request correction of inaccurate information

Delete: Request deletion of your personal information (subject to legal retention requirements) Data Portability: Request your information in a portable, machine-readable format

Opt-Out: Opt out of targeted advertising and data sales (we do not sell your data)

No Data Sales

We do not sell your personal information to third parties. If this practice changes, we will notify Maryland residents and provide an opt-out mechanism.

Data Protection Impact Assessment

If we use your information for targeted advertising, profiling, or automated decision-making, we conduct a Data Protection Impact Assessment and document it in our compliance records. You may request a copy of this assessment.

Contact for MODPA Questions

For questions about your rights under MODPA or to exercise your privacy rights, contact us at: Email: [email protected]

Subject Line: "Privacy Rights Request"

12. California-Specific Disclosures (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA).

Your CCPA Rights

You have the right to:

Know: Request what personal data we collect and how we use it

Delete: Request deletion of your personal information

Opt-Out: Opt out of the sale of personal information (we do not currently sell personal data) Correct: Request correction of inaccurate data

Limit Use: Limit our use of sensitive personal information

No Data Sales

We do not currently sell your personal information. If this practice changes, we will provide a "Do Not Sell My Personal Information" link on our homepage.

How to Exercise Your Rights

Contact us at [email protected] with "CCPA Request" in the subject line. We will respond within 45 days.

No Discrimination

We will not discriminate against you for exercising your CCPA rights.

13. Children's Privacy

Our Site and products are intended exclusively for adults 21 years of age and older. We do not knowingly collect personal information from individuals under 21. If we discover that we have inadvertently collected information from someone under 21, we will delete it immediately.

For information about COPPA (Children's Online Privacy Protection Act) or concerns about minors accessing our Site, please contact us at [email protected].

14. SMS Communications

By providing your phone number, you may opt in to receive SMS messages about your order status, delivery times, and customer service. Message frequency varies. Standard message and data rates apply.

To Opt Out of SMS: Reply STOP to any SMS message we send. You will be unsubscribed within 24 hours. You may still receive SMS messages related to existing orders for a brief period.

For SMS Support: Text HELP to get assistance, or email us at [email protected]. We will never share your phone number with third parties for marketing purposes without your consent.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make changes, we will:

Post the updated Privacy Policy on this page

Update the "Last Updated" date at the top of this page

Notify you via email if the changes are material (if you have an account with us)

We encourage you to review this Privacy Policy periodically. Your continued use of the Site after changes are posted constitutes your acceptance of the updated Privacy Policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Funnels LLC

9215 51st Avenue

College Park, MD 20740

Email: [email protected]

Phone: [Insert phone number]

Customer Support Hours: Monday–Friday, 9:00 AM – 5:00 PM EST

For Privacy Rights Requests:

Email: [email protected]

Subject Line: "Privacy Rights Request – [Access/Delete/Correct]"

17. Consent

By using our Site, you consent to the collection, use, and sharing of your personal information as described in this Privacy Policy.