Effective date: 1st May 2024

1. Introduction

This Privacy Policy outlines JA CIGAR LLC’s commitment to protecting the privacy of individuals who visit our website and interact with our services. As a cigar distributor in Puerto Rico, we understand the importance of maintaining confidentiality and integrity in handling personal data.

This document provides detailed information on how we collect, use, and safeguard the personal information provided to us through our website, It also describes your choices regarding our use of your data and how you can access and update this information.

The scope of this policy encompasses all data collection and processing activities conducted by JA CIGAR LLC.

2. Definitions

For this Privacy Policy, the following terms are defined:

  • Personal Data: Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
  • Processing: Any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • Data Subject: Any living individual using our website and is the subject of Personal Data.
  • Cookies: Small text files placed on your device by websites you visit. They are widely used to make websites work or work more efficiently, as well as to provide information to the site’s owners.

3. Consent

By using our website, you consent to our Privacy Policy and agree to its terms. We will obtain further explicit consent from you before collecting or using your data for purposes not disclosed in this Privacy Policy. You have the right to withdraw your consent at any time. To withdraw your consent, please get in touch with us using the contact information provided in the Contact Information section of this policy. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

4. Information Collected

JA CIGAR LLC collects various types of personal data to enhance its website’s functionality and conduct business effectively. This data includes, but is not limited to:

  • Contact Information: Your name, email address, and phone number when you submit inquiries through our “Get in Touch” section.
  • Technical Data: IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
  • Usage Data: How you use our website, products, and services.
  • Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

This information is collected through direct interactions (such as filling in forms on our site), automated technologies like cookies, and third-party analytics tools that monitor and analyze web traffic.

5. Use of Collected Information

The personal data collected by JA CIGAR LLC is used for several business purposes:

  • To Provide and Maintain our Service: This includes monitoring the usage of our service and website.
  • To Manage Your Account: To manage your registration as a service user. The Personal Data you provide can give you access to different functionalities of the service available to you as a registered user.
  • For Customer Communication: We will contact you by email, telephone call, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications, regarding updates or informative communications related to functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation.
  • To Provide You with News, Special Offers, and General Information about Other Goods, Services, and Events We offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  • To Manage Your Requests: To attend to and manage your requests for us.

6. Lawful Basis for Processing

JA CIGAR LLC processes your data under the following lawful bases:

  • Consent: You have given explicit consent to process personal data for specific purposes.
  • Contract: The processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
  • Legal Obligation: The processing is necessary for compliance with a legal obligation to which we are subject.
  • Vital Interests: The processing is necessary to protect your vital interests or those of another natural person.
  • Public Interest: The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
  • Legitimate Interests: The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

7. Data Sharing and Disclosure

We may share your personal data with third parties under the following circumstances:

  • Service Providers: We may share your data with third-party companies and individuals that provide services on our behalf to help us with our business activities such as hosting, data analysis, IT services, customer service, email delivery, and marketing efforts.
  • Legal Requirements: We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
  • Business Transfers: In the event that JA CIGAR LLC is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
  • Other Situations: We may disclose your information also to third parties to protect the security or integrity of our Service, to protect against legal liability, to enforce our terms and conditions, to protect our rights or property or the safety of our users or others, or to investigate or prevent possible wrongdoing in connection with the Service.

8. International Data Transfers

JA CIGAR LLC operates primarily within Puerto Rico, but it may involve transferring your collected data to and from other countries for various business needs. The international transfer of personal data is conducted in accordance with applicable law and includes appropriate safeguards designed to ensure the security of your personal data. We ensure that all data transfers comply with the General Data Protection Regulation (GDPR) if EU residents are involved, and with similar standards for other regions. Such transfers are only executed under the following conditions:

  • Adequate Protection: The country to which the personal data is transferred has been deemed to provide an adequate level of protection for personal data by the relevant authorities.
  • Standard Contractual Clauses: We use standard contractual clauses approved by the European Commission or other relevant authority ensuring personal data protection.
  • Consent: In cases where other mechanisms cannot be implemented, we rely on your explicit consent for the specific transfer, after informing you about the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards.

9. Data Security

JA CIGAR LLC is committed to protecting the security of your personal data. We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. These measures include:

  • Encryption: Using SSL technology to encrypt data during transmission.
  • Secure Networks: Utilizing only secure networks that are protected with firewalls and intrusion detection systems.
  • Access Controls: Limiting access to personal data to those employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations.
  • Regular Audits: Conducting audits regularly to ensure that our privacy and security policies are adhered to.
  • Incident Response: We maintain an incident response plan and notify affected individuals and authorities as required by law in the event of a data breach.

10. Data Retention  

Can achieve those purposes through other means, and the applicable legal requirements. Once the purposes for which personal data was collected are no longer applicable, personal data is either deleted or anonymized. Specific retention periods for different aspects of your personal data can be provided upon request.

11. Cookies and Tracking Technologies

Our website utilizes cookies and similar tracking technologies to track the activity on our service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service. We use the following types of cookies:

  • Essential Cookies: Necessary for the website to function and cannot be switched off in our systems.
  • Performance Cookies: Allow us to count visits and traffic sources so we can measure and improve the performance of our site.
  • Functional Cookies: Enable the website to provide enhanced functionality and personalization.
  • Targeting Cookies: May be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

12. User Rights

As a data subject, you have certain rights regarding your personal data, including:

  • Right to Access: You can request a copy of the personal data we hold about you.
  • Right to Rectification: You can request that any incomplete or inaccurate information we hold about you is corrected.
  • Right to Erasure: You can request that we delete your personal data under certain conditions.
  • Right to Restrict Processing: You can request the restriction of processing of your personal data.
  • Right to Data Portability: You can request the transfer of your personal data to another organization, or directly to you, under certain conditions.
  • Right to Object: You can object to the processing of your personal data, under certain conditions, including processing for direct marketing.
  • Right to Withdraw Consent: Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time.

13. Children’s Privacy and COPPA Compliance

In compliance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect, use, or disclose information from children under the age of 13 without verifiable parental consent. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us at the contact information provided in this policy.

14. Third-Party Websites

Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

15. Social Media Widgets

Our website includes social media features, such as the Facebook “like” button and widgets, such as the “share this” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.

16. Email and Communications Preferences

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails. Alternatively, you can request to be excluded from marketing communications by contacting us directly. Please note that customers cannot opt out of receiving transactional emails related to their account with us or our services.

17. Changes to the Privacy Policy

We may update our Privacy Policy from time to time to reflect changes to our data practices. We will notify you of any significant changes by posting the new Privacy Policy on our website and updating the effective date at the top of this policy. We encourage you to review this Privacy Policy periodically for any changes. Minor changes will be effective immediately upon posting, while significant changes will take effect 30 days after their posting on our website. Your continued use of our services after such modifications will constitute your acknowledgment of the modified Privacy Policy and agreement to abide and be bound by the updated policy.

18. Applicable Privacy Laws Compliance

JA CIGAR LLC is committed to protecting your privacy and adheres to several privacy laws and regulations:

  • Local Laws (Puerto Rico): We comply with Puerto Rico’s privacy and cybersecurity laws, which regulate the collection, use, and storage of personal data by both government agencies and private entities. Puerto Rico has enacted specific regulations like the Puerto Rico Data Protection Act, which outlines stringent guidelines for handling personal data and imposes penalties for non-compliance.
  • Federal U.S. Laws: We adhere to applicable U.S. federal laws, including those enforced by the Federal Trade Commission (FTC), such as the Children’s Online Privacy Protection Act (COPPA) for protecting children’s privacy online, and various data breach notification laws that apply across all U.S. states and territories, including Puerto Rico.
  • International Laws: For users outside of the United States, such as those in the European Union, we ensure compliance with the General Data Protection Regulation (GDPR) which mandates rigorous data protection standards and offers individuals substantial control over their personal data. This adherence helps safeguard the rights of all our users, maintaining a high standard of privacy and security globally.
  • California Consumer Privacy Act (CCPA): Even though our primary operations are in Puerto Rico, we also comply with the CCPA, which applies to businesses that handle the personal information of California residents. This law provides California residents with the right to know about the personal data collected about them and the purpose for which it is used, and they can request the deletion of their personal information.

19. Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy policy and applicable data protection laws. If you have any questions about this privacy policy or our privacy practices, please get in touch with our DPO at:

  • Email:

20. Governing Law

This Privacy Policy is governed by the laws of Puerto Rico without regard to its conflict of law provisions. Any disputes arising from or relating to the subject matter of this policy shall be finally settled by arbitration in Puerto Rico, conducted in English, and governed by Puerto Rican law.

21. Dispute Resolution

If you have any complaints regarding our compliance with this policy, you are encouraged to contact our Data Protection Officer. If you are not satisfied with the resolution of your complaint, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

22. Contact Information

For any questions, concerns, or clarifications regarding this privacy policy or data protection practices, please contact us at:

  • Email:

23. Effective Date

This Privacy Policy is effective as of 1st May 2024, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

24. Accessibility

We are committed to ensuring that our privacy practices are accessible to all users, including those with disabilities. If you require any assistance or wish to communicate in an alternative format, please contact us using the information provided in the Contact Information section.

25. Regulatory Authority

The regulatory authority overseeing data protection in Puerto Rico is the Puerto Rico Department of Justice. Contact information and further details about the regulatory authority can be accessed directly from their website or by contacting our Data Protection Officer.