Notice at Collection
Sojern provides intelligent digital marketing solutions for the travel industry to engage and convert travelers. This page (the “Notice at Collection”) supplements Sojern’s Privacy Policy and provides an overview of Sojern’s privacy practices. We provide this Notice at Collection pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”.)
Categories of Personal Information Collected
We may collect the following statutory categories of personal information under the CCPA from or about you, depending on how you interact with Sojern - e.g., if you are a client or partner, a recipient of Sojern advertisements, or a candidate for employment. A full description of the different types of personal information we collect in different situations is available here.
- Identifiers
- California Consumer Records (as defined in California Civil Code §1798.80)
- Commercial information
- Internet or Network information
- Geolocation data (general only)
- Professional or employment-related information
- Inferences
- Sensitive personal information, including identification documents and racial or ethnic origin (for employment candidates only)
Purposes for which Personal Information is Collected
- The purposes for which we collect Personal Information also depend on how you interact with Sojern. For details on the purposes for which we collect personal information in different situations, see the section of the Privacy Policy titled "Personal Information We Collect and How We Use Personal Information".
Categories of Personal Information “Sold” or “Shared”
- While we do not sell personal information for monetary compensation, under some United States privacy laws the disclosure of your pseudonymous personal information to ad exchanges, ad networks, and other companies in the programmatic advertising ecosystem, may constitute a “sale” or “sharing” of personal information, even absent an exchange of money.
- You can opt out of targeted advertising from Sojern, including “sales” or “sharing”, at the following link: https://www.sojern.com/privacy/opt-out-data.
Retention
- We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide the Services to you or others, or to comply with applicable legal, tax, or accounting requirements). We also retain and use personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- When we have no ongoing legitimate business need to process your personal information, we either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we securely store your personal information and isolate it from any further processing until deletion is possible. When it is no longer necessary and relevant to provide our Services, we may aggregate or de-identify your personal information and combine with other non-personal information to provide insights and statistics.
- We retain raw, cookie-level data associated with our Services for up to 24 months. At the time of collection, we may create aggregated data that cannot be re-associated with an individual cookie. We may retain this aggregated data for a longer period as required by law or otherwise necessary to resolve a dispute and enforce our agreements.
- Sojern cookies expire in 12 months, although your additional use of other businesses’ websites may result in the placement of a new cookie.
Our full privacy policy is available at https://www.sojern.com/privacy/privacy-policy.
