Last Updated June 1, 2020
‘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.
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.
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:
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:
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:
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.
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:
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 email@example.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.
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:
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:
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:
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 firstname.lastname@example.org. We will take steps to delete such information from our files as soon as possible.
We may share your personal information to the following categories of recipients:
We rely on a number of legal bases to collect, use, and disclose your personal information, including:
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.
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.
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 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.
Our Standard Contractual Clauses or Privacy Shield certification can be provided on request.
You have the following privacy rights at any time:
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 email@example.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.
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 firstname.lastname@example.org.
If you have any questions or concerns about our collection or use of your personal information, email us at email@example.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:
255 California Street Suite 1000
San Francisco, CA 94111
Sojern International Ltd.
34-37 Clarendon Street
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.