Sojern Privacy Policy

Last Updated June 1, 2020

Sojern respects your right to privacy. This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. It applies to individuals who engage our services (“Services”), access our online properties, such as sojern.com (“Website”) or who participate in our recruitment activities. This Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. This Privacy Policy was written in English and if a translated version conflicts with the English version, the English version controls.

WHO WE ARE; WHAT WE DO

‘Sojern’ is the trading name of Sojern, Inc., headquartered in San Francisco, California, and operating globally. We provide intelligent digital marketing solutions for the travel industry to engage and convert travelers. For more information about Sojern and our Services, visit our Website.

CHART OF DATA CATEGORIES, SOURCES, PURPOSES, AND DISCLOSURES

You can visit the Privacy Center for a chart summarizing the categories of data we collect, use, and disclose and their different sources, purposes, and disclosures. 

INFORMATION WE COLLECT; HOW WE USE INFORMATION
Provide Services

Our Services help businesses identify and advertise to in-market travelers for purposes of online behavioral advertising; optimize advertising campaigns across multiple channels and devices; increase web traffic and brand awareness; and use local market and competitive insights. For more information about our Services, visit our Website.

Personal information from our clients and partners

When engaging with us to provide Services, we may collect and use personal information which is necessary for our business relationship. We use personal information to manage our business relationship, administer our Services, and communicate with you. This information may include:

  • Name and job title;
  • Company or organization;
  • Contact information, including email address and telephone number;
  • Financial information, including payment card and other payment related information;
  • Any other personal information relating to you or other third parties which you may provide to us for the purpose of receiving our Services.

When we provide Services for our clients and partners 

When clients and partners engage with us to provide Services, we may collect and use your personal information for the performance of those Services. Those Services include:

  • Delivering advertising campaigns and more relevant content to our clients’ potential travelers across the Internet, mobile applications, and other channels;
  • Tracking travelers across devices and browsers for purposes of online behavioral advertising;
  • Creating audience segments, using data collected from our pixels and partners, for our clients to optimize the relevance and performance of their advertising campaigns; and
  • Delivering intelligent insights for our clients and partners to better understand their potential customers, the advertisements they see, and how they interact with online content.

To provide our Services we use aggregated and pseudonymized information collected directly from our clients, who have access to this information with consent of their users. In this case, we are a service provider or data processor acting at the direction of those clients, and accordingly, their privacy policies apply, and this Privacy Policy does not apply to personal information that we hold on their behalf. We also use aggregated and pseudonymized information collected directly from our partners, who have access to this information with consent of their users. In these instances, we are an independent data controller and our partners’ privacy policies and this Privacy Policy may apply to your personal information. 

We may enable clients and partners to use pixels that automatically collect raw, cookie-level data from their online properties to share with us. (Similar technologies to a pixel are used when you view an email from our clients or partners that has a Sojern tag, use a mobile application with a Sojern SDK installed, or see or interact with an online advertisement that was placed through our Services). The information may include: 

  • Pseudonymous IDs, such as cookie ID, mobile advertising ID (MAID), TV identifier, hashed email address, and other persistent alpha-numerical identifiers that do not, by themselves, personally identify a specific individual;
  • Technical data, such as IP address, device type, browser type, date and time stamp of clicks and web visits, URLs, and other technical information;
  • Customer relationship management (CRM) data belonging to our clients and partners that reflects their online and/or offline interactions with individuals;
  • Audience data, such as information of the preferences, interests, and consumer segment in aggregated and pseudonymized form. 

Our clients and partners may use our pixels to place cookies on your browser or device. Cookies do not tell our clients, partners or us who you are as an individual and where you live. Clients and partners may use information in cookies to tailor online advertising to someone who may share certain interests or propensities with members of an aggregated group, for reporting and analytics about their websites or services, and more. Additionally, our clients, partners, and advertising service providers may request we limit the tracking of ads, and should we receive these requests, we will cease tracking and limit the use of any data collected from our pixels to research and development purposes only. We may use information about cookies to measure the effectiveness of our Services like ad campaigns for our clients and partners. Our clients and partners’ use of our pixels does not mean we endorse their privacy policies or practices. If your personal information is collected and used by other businesses, refer to their terms of use and privacy policies for information about your personal information.

You may choose to opt-out of cookie-based behavioral advertising by following opt-out instructions in the Privacy Center. We comply with opt-out requests by placing an “opt-out” cookie on your computer or device, so, if you clear your cookies on that computer or device, we are unable to read the “opt-out” cookie. You may also change your browser settings so that cookies cannot be placed on your device and modify your mobile device settings for seeing advertisements. Additionally, you may choose to opt-out of receiving browser-based targeted advertisements from us by following opt-out instructions here:

If you wish to exercise your privacy rights related to the personal information provided by our clients or partners, we may help by directing your requests to them so they may appropriately respond. 

We do not collect sensitive personal information, such as racial or ethnic origin, political or religious beliefs, information about health conditions or treatments, or other similar or related information in our Services.

Our Website

The personal information that we may collect about you when you visit our Website broadly falls into the following categories:

Information that you provide voluntarily

We collect personal information that you provide voluntarily through our Website, for example when inquiring about or registering for our Services and events. We may use your information to send marketing and promotional materials to you. The information we collect about you may include some or all of the following:

  • Name and job title;
  • Company or organization;
  • Contact information, including email address and telephone number;
  • Demographic information such as preferences and interests;
  • Information pertinent to fulfilling our Services to you; and
  • Any other personal information that you voluntarily choose to provide to us.

We will be clear with the reasons why we ask you to provide other personal information that was not identified above at the point we collect such information. 

You may choose to not receive marketing emails by following the “unsubscribe” link found in these emails or email us at mktg@sojern.com. You may choose to opt-out of receiving browser-based targeted advertisements from Sojern by following opt-out instructions in the TrustArc Preference Manager

Information we collect automatically

When you visit our Website, we may collect certain personal information automatically from your browser, collectively, ‘technical data’. Technical data may include your IP address, internet service provider (ISP), device type, browser type, date and time stamps, and other technical information. We collect and use this information to help us understand visitors to our Website, respond to your requests, process transactions you initiate, and improve the quality and relevance of our Website. 

When you visit our Website, we may collect personal information automatically using cookies. Cookies do not tell Sojern who you are as a person and where you live. We use cookies to provide Website functionality, deliver personalized content to you, measure Website performance, and deliver advertising relevant to you based on your interests. 

You may choose to opt-out of browser-based activities occurring on our Website by following the opt-out instructions in the Privacy Center. You may also change your browser settings so that cookies cannot be placed on your device and modify your mobile device settings for seeing advertisements. Additionally, you may choose to opt-out of receiving browser-based targeted advertisements from us by following opt-out instructions here:

Recruit Candidates

We collect information from and about candidates in connection with available employment opportunities at Sojern. We use your personal information to match your qualifications with the specific roles offered at Sojern. This information may include:

  • Resume or curriculum vitae;
  • Identification documents;
  • Academic records;
  • Work history; and
  • Employment and personal references. 

We may collect sensitive personal information where we have an employment law obligation to do so, the information is relevant to place future employment benefits, or with your explicit consent. We do not use sensitive personal information to determine credit worthiness or eligibility for insurance, employment, housing, etc. We may need to conduct criminal background checks for some candidates for eligibility to work at Sojern. On a voluntary basis, we may also ask you to provide diversity information such as your race/ethnicity or veteran status for diversity monitoring purposes.

We may collect personal information from candidates from the following sources: 

  • Directly from you, for example, when applying for a position through our careers Website;
  • From recruitment agencies that identified you as a potential candidate;
  • Through publicly available sources online, for example, where you have a professional profile posted online; and
  • By reference or word of mouth, for example, through a referral from an individual connected to you. 

CHILDREN’S INFORMATION

We do not direct or advertise our Services to children under the age of thirteen (13) or other minimum age as required by local law. We do not knowingly collect personal information from children. If you are a child or you are a parent or legal guardian of a child and personal information was provided to us, you may alert us at sojernprivacy@sojern.com. We will take steps to delete such information from our files as soon as possible.

SHARING INFORMATION

We may share your personal information to the following categories of recipients:

  • To our subsidiaries and affiliates under the Sojern trade name, as well as partners and third party services providers who provide data processing services to us (for example, for Website spam security service; or if you are a candidate, from recruitment agencies we have engaged); 
  • To any competent law enforcement body, regulator, government agency, court or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation, such as complying with a subpoena or other legal process, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; and
  • To a person you have given us your consent to disclose to.

OTHER COLLECTION, USE, AND DISCLOSURE

We do not collect, use or disclose personal information other than as described in this Privacy Policy, except:

  • Information collected from third-party or publicly-available sources;
  • As a data processor or service provider at the direction of our clients;
  • With your express permission, where consent is appropriate;
  • Where permitted by our client or partner agreements, for internal use, research, fraud prevention and detection, and product development;
  • To investigate, identify, respond to cyber security threats, and assist others of the same;
  • To respond to law enforcement investigations;
  • To respond to lawful requests and legal process in civil, criminal, or investigative matters, including to meet national security or law enforcement requirements;
  • To enforce agreements, terms and conditions, and policies, and protect our legal rights;
  • To protect the personal safety of Sojern employees, our clients and partners or any person;
  • In an aggregated or de-identified form that does not directly or indirectly identify you;
  • With third party service providers who work on our behalf; and
  • In connection with any purchase, merger or acquisition of any part of our business.

LEGAL BASES

We rely on a number of legal bases to collect, use, and disclose your personal information, including: 

  • As necessary to provide the Services and fulfill our contractual obligations;
  • With your consent;
  • To comply with a legal obligation, court order, or to exercise and defend legal claims;
  • To protect your vital interests or those of others; and
  • For Sojern’s or a third party’s legitimate interests, and not overridden by your interests and fundamental rights and freedoms. 

SAFEGUARDS TO PROTECT INFORMATION

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. We have implemented policies that include administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, and disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

RETENTION OF INFORMATION

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 that are commercially valuable to us. 

Sojern cookies

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.

INTERNATIONAL TRANSFERS

Our Website servers are located in the United States. To deliver our Services, we use a cloud hosting service provider that distributes traffic across servers located in multiple geographies, known as geographic load balancing. Data is then transferred to data centers located in the United States for processing. Our subsidiaries, affiliates, partners, and third party service providers operate around the world. This means that we collect your personal information and it may be processed in countries that may have data protection laws that are different to the laws of your country.

We participate in and have certified compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework for the processing and onward transfers of personal information from EEA, Switzerland, and U.K. (see Privacy Shield List). We are responsible for onward transfer liability provisions and are subject to the enforcement powers of the U.S. Federal Trade Commission. You may be entitled to invoke binding arbitration under certain conditions when other dispute resolution procedures have been exhausted.

We have taken appropriate safeguards to require that the personal information we process remains protected in accordance with this Privacy Policy when transferred internationally by our partners and third party service providers. The safeguards we have taken include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to non-EEA entities, which requires them to protect personal information they process from the EEA in accordance with European Union data protection laws. Further details on appropriate safeguards with our partners and third party service providers can be provided upon request.

Our Standard Contractual Clauses or Privacy Shield certification can be provided on request.

YOUR PRIVACY RIGHTS

You have the following privacy rights at any time: 

  • You can access, correct, update or request deletion of your personal information;
  • You can object to the processing of your personal information, ask us to restrict processing of your personal information, or request we port your personal information;
  • You can opt-out of marketing communications we send you;
  • If we collected your personal information with your consent, you can withdraw your consent; 
  • You can request information about our collection, use and disclosure of your personal information, including: (i) a description of the categories of personal information we have collected or shared; (ii) a description of the categories of sources from which we have collected your personal information; (iii) a description of the categories of third parties with whom we have shared your personal information; (iv) a description of our purposes for collecting and sharing your personal information; and (v) your personal information for direct marketing purposes; and
  • You can complain to a data protection authority about our collection and use of your personal information. 

You can visit the Privacy Center to exercise certain privacy rights with ease. You can also exercise these rights by contacting us by email at sojernprivacy@sojern.com. Contact details for data protection authorities in the European Economic Area, Switzerland, and certain non-European countries (including the US and Canada) are available on the European Commission website. We respond to all requests received from individuals wishing to exercise their privacy rights in accordance with applicable data protection laws.

We are prohibited by law from treating you in a discriminatory manner as a result of your choice to exercise any rights you have under data protection law. 

CALIFORNIA AND NEVADA RESIDENTS

We do not share your personal information with third parties who are not our clients and partners for their direct marketing unless you authorize us to do so. You have certain rights as a California or Nevada resident and for more information about these rights, refer to the “Your Privacy Rights” section of this Privacy Policy or submit a request to sojernprivacy@sojern.com

DO NOT SELL MY PERSONAL INFORMATION: Under California law, the disclosure of your personal information to ad exchanges, ad networks, and other companies in the programmatic advertising ecosystem, may constitute a sale of personal information, even absent an exchange of money. You can submit your opt-out request for the sale of your personal information by visiting the Privacy Center. You can also exercise these rights by contacting us by email at sojernprivacy@sojern.com

UPDATES

We may update this Privacy Policy from time to time in response to legal, technical or business developments, in which case we will revise the “last updated” date at the top of this Privacy Policy. When we update our Privacy Policy, we will inform you by posting a notice on the Website prior to such changes becoming effective, which will be consistent with the significance of the changes we make.

CONTACT US

If you have any questions or concerns about our collection or use of your personal information, email us at sojernprivacy@sojern.com

The entity that decides how and for what purposes we use your personal information (“data controller”) for the Website and Services is Sojern, Inc. If you are a candidate seeking employment at Sojern, the data controller is the relevant Sojern entity with whom you have engaged. Address details for all Sojern entities are available on the Contact Us page.

You may contact us via postal mail to the addresses below:

Sojern, Inc.
Attention: Privacy
255 California Street Suite 1000
San Francisco, CA 94111

EU Representative:
Sojern International Ltd.
Attn: Privacy
34-37 Clarendon Street
Dublin 2
Ireland

If you have an unresolved query or data concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

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