Last Updated: October 15, 2018
Sojern, Inc. (“Sojern,” “We,” “Us,” and “Our”) is a traveler audience engagement platform that delivers marketing and media solutions, predictive advertising technology, distribution, monetization and insights products for global travel conglomerates and independent providers specializing in the airline, hotel, car, cruise, railway, and tourism categories (“Sojern Products”).
Sojern supports initiatives of greater transparency and control for users and participates in the following industry self-regulatory efforts:
Sojern is a member of the U.S.-based Digital Advertising Alliance (“DAA”) and adheres to DAA’s Self-Regulatory Principles for Online Behavioral Advertising. Sojern subscribes to the DAA opt-out platform which offers U.S. consumers choices to opt-out from behavioral advertising. For more information, please follow this link to www.AboutAds.info.
Sojern is a member of the European Interactive Digital Advertising Alliance (“EDAA”) and adheres to EDAA’s Self-Regulatory Principles. Sojern subscribes to the EDAA opt-out platform which offers European consumers choices to opt-out from behavioral advertising. For more information please follow this this link to www.youronlinechoices.eu.
Sojern adheres to the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Canadian-based Digital Advertising Alliance (“DAAC”). Sojern subscribes to the DAAC opt-out platform which offers Canadian consumers choices to opt-out from behavioral advertising. For more information please follow this link to http://youradchoices.ca
Prior to learning about Sojern’s privacy practices, it may be helpful to familiarize yourself with some of the key terminology we use when describing the technology and processes surrounding the Sojern Platform. We’ve prepared a helpful guide for you to review here.
Sojern’s traveler audience engagement platform (the “Platform”) ingests intent signals and filters this data to build out traveler profiles (“Traveler Profiles”). We obtain these intent signals from our various data partners (“Data Partners”) and advertising clients (“Clients”). We then use this data to help our Clients build advertisements for their end users who visit their websites or mobile applications (“End Users”) and advertise to them through major advertising exchanges and publishers worldwide. The Platform allows our Clients to deliver relevant advertisements to individual end users, by displaying products that our Client’s end user might be interested in based on their recent browsing behavior or mobile application behavior, including delivering advertisements across a user’s different devices. For example, if you visit and browse on either a website or a mobile application through a Sojern Platform Data Partner, you may see personalized ads based on your prior browsing history on another website or mobile application. Click here for more information about ‘Interest-Based Advertising’.
Sojern Products do not intentionally collect any information from End Users that would personally identify you in the real-world, such as name, address, email address, or phone number. However, as various global laws define personal information differently, Sojern will comply with the respective laws of the location in which the data is collected. We (or service providers on our behalf) collect the following data from End Users to be used in our various advertising related products: (1) website visitor data (including mobile websites) collected via placement by our Clients or Data Partners of Sojern pixels on their respective websites, (2) mobile application data through select Data Partners who enable such information sharing, (3) location-based information, (4) cross-device data, which brings together the various data points, as described more fully below, and (5) information received from Third Party sources.
Website (& Mobile Website) Visitor Data Collection
Through the implementation of Sojern pixels that our Clients or Data Partners place on their websites (including mobile websites), Sojern collects certain information about our Client’s End Users’ actions on that website and places a cookie on the End User’s browser or device. The type of information collected through the placement of the pixel includes commonly associated information from your device or Internet access, as well as attributes that are unique to our Data Partners.
Information commonly associated with website visitors includes: IP address, browser type, browser version, Operating System (OS), OS version, HTTP referrer, event time and event type. We may also use Third Party tools to infer additional data such as proximate location information from an IP address.
Unique attributes, which we often refer to as ‘intent signals’, may include specific web pages visited, travel search requests with specified search entry variables, and travel search booking results. These variables and results include many of the fields you enter in a travel search request, such as the type of travel, dates, locations, properties, numbers of guests, number of rooms, amenities, and other interests. If a travel loyalty ID number (e.g., frequent flier number) is entered and passed through during a booking, Sojern will randomize this information to prevent either Sojern or our travel partner(s) from being able to connect it back to a known person.
Mobile Application Data
We also receive, but do not directly collect, certain mobile device and application data through Third Party service providers, including Mobile Attribution Vendors that our Clients or Data Partners may contract with to work with Sojern. These Third Parties, including the Mobile Attribution Vendors, are solely responsible for compliance with the terms of the contracts with the Data Partners or Clients, their respective privacy policies, guidelines or rules set forth by the Mobile Attribution Vendors, including, without limitation, any limits on what data they can pass to Third Parties, such as, Sojern.
The types of mobile device and application data that we receive via these Mobile Attribution Vendors includes intent signals as well as device-specific attributes including mobile device type, mobile device brand, mobile device model, phone carrier, mobile device language, Operating System (OS), OS version, Advertising ID (Apple IDFA or Google Advertising ID), IP address, Wi-Fi status, GPS, and other attributes.
As noted, Sojern Products may receive various data attributes that may infer or identify your location. These location data attributes may include geographic information you enter in a travel search request or transaction, as well as from your IP address, Wi-Fi, Bluetooth, or mobile device GPS. See below in the ‘Your Choices’ section for more information on restricting access to this type of information.
In order to facilitate the most relevant ads possible, Sojern works with various service providers who assist with delivering similar ads to end users across devices including computers, tablets, and mobile phones. These service providers may attempt to synchronize the IDs Sojern receives with IDs collected from other data partners. For example, if you see an ad that Sojern helped facilitate on your computer web browser, you may see a similar ad on a mobile website or mobile application facilitated through our cross-device synchronization process. See below for more information on how we use this information and your choices for continued tracking.
Information Received from Third Party Sources
In addition to data collected through our Data Partners and Clients, Sojern may work with various third parties to supplement or append data to our Products. This may include unique user data that is synchronized with third party data providers, inferred data based on interest-categories, or aggregated information. Examples of appended information may include demographics such as gender, age, marital status, regional census data, and income or psychographics such as lifestyle interests. In any case, Sojern does not intentionally append or synchronize any information that would personally identify you in the real world. However, as various global laws define personal information differently, Sojern will comply with the respective laws of the location in which the data is collected.
Please note that Sojern does not intentionally collect or receive any information that may be deemed ‘sensitive’ such as protected health information or credit-worthiness.
Information Collected From Clients
Sojern collects data from its Clients in order to communicate and provide services. This may include name, physical address, email address, mobile device advertising ID, and IP address. In addition, Sojern collects third-party information from its Clients through Sojern Products. For instance, a Client may provide us with another person’s information in order add them as a user to the system. Sojern will only use the information collected from Clients for the purposes detailed in this policy and in accordance with the terms of the applicable agreement(s).
Sojern’s Products use data for three distinct purposes. The first is ingesting intent signals from across our Data Partners and Clients to create unique traveler profiles across web and mobile experiences. The second is utilizing a proprietary learning algorithm to combine data from advertising campaigns and ID synchronization efforts to create the most relevant campaign opportunities. Finally, the data is used to enable our advertiser clients to utilize the Sojern Platform with real-time advertising campaigns.
Creation of Traveler Profiles
Like most advertising services, we use a combination of pixel tags and cookies to recognize your preferences and effectively administer our Service. A pixel tag is a small image placed on a website to track visitor activity including when advertisements are delivered or clicked-on. Pixel tags are often used in combination with cookies. A cookie is a small text file containing a string of characters that is placed on your browser or device by a host when you visit a website. When you visit the website again, the cookie allows that host to recognize your browser.
We assign a unique randomized Sojern profile cookie ID to each user (“Sojern Profile ID”). The Sojern Profile ID is a unique technical ID that we assign to users that we see across the web — i.e. a unique cookie sighting. Any time we see the same Sojern Profile ID, we append any data collected on that visitor to their Sojern Profile for future reference. For example, if you search for a hotel in a certain city through a travel search Data Partner, and then visit a specific hotel website that is also a Sojern Client, we will recognize that you visited both websites and combine these two visits together in your Sojern Profile. When you see an ad for the same hotel you visited on another website, it may be because the advertising service used the Sojern Platform to help identify the ad as relevant to your interests.
As previously noted, Sojern works with numerous service providers to attempt to facilitate a connection between web and mobile users. These cross-device vendors help us add your mobile website or application visits to your Sojern Profile for relevant advertising across web and mobile experiences. Some of these vendors may collect your unique mobile advertising ID through your operating system, and in the ‘Your Choices’ section below we describe various ways for you to control this specific use. However, in most cases the connection between a mobile and web user will be inferred or based on a high probability of it being the same user.
Improving Sojern Products Through Intelligent Algorithms
The Sojern Platform is designed to learn from every user, and continually be optimized to deliver the most relevant ads across the web for an improved user experience. In doing so, Sojern Profiles are continually updated with new information, which may include your initial search inquiry all the way through to when you book your trip. We use this data in numerous ways to improve the effectiveness of our Clients’ advertising campaigns. For example, following the recognition of a hotel booking, the Sojern Platform could then intelligently inform our advertisers to ‘turn off’ ads that may no longer be relevant to your hotel search request.
Sojern will use any data collected or received to improve the effectiveness of existing Sojern Products and the user experience, as well as to create new products. This may include combining, aggregating, and developing new methods of analyzing or reporting data from, and with, our Data Partners or Clients.
Synchronization For Ad Delivery
Sojern is not an ‘ad server’ or ‘ad network’, which means we do not actually select ad placements or deliver any ads directly to you. For the Sojern Platform to be used, we need to synchronize our IDs with other parties who then select and facilitate ad delivery to web or mobile users. This synchronization process involves matching Sojern’s cookie or other IDs during an active web or mobile experience. For example, when you visit a Sojern Data Partner like a travel search website and the Sojern cookie is created, Sojern may immediately ‘call’, or be called from, another service provider to synchronize IDs and enable a future relevant ad delivery. Sojern then works with various advertising networks, including Google and Facebook, to synchronize our cookies and deliver relevant advertising through their platforms.
Cookies have an expiration date, and Sojern has set ours to expire in two years. However, this expiration is contingent upon not ‘seeing’ that cookie again during that two-year period. Should you visit a Sojern Data Partner or Client prior to the two-year period being complete, your existing Sojern cookie will be updated with a new two-year expiration date.
The Sojern Platform is designed to service both Data Partners and Clients. We may share any information in the Sojern Platform with our Data Partners, Clients or service providers if it is necessary to facilitate or manage advertising campaigns. These Data Partners and Clients may use this information (and similar information collected elsewhere) for purposes of delivering targeted advertisements to you when you visit non-Sojern related websites.
In addition, we may disclose information to identify suspicious activity, resolve disputes or investigate problems. We may use or disclose information, including Personal Information, if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose information where, in good faith, we think it is necessary to protect the rights, property, or safety of Sojern, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests.
We may also share certain anonymous and aggregated information publicly, including with users, partners, prospects or the press in order to demonstrate how Sojern is used, spot industry trends, or to provide marketing or press materials for Sojern. Any aggregated information shared this way will not contain any personally identifiable information.
You have many options to block, delete or opt-out of Sojern’s tracking methods. In every contemporary Internet browser, you may elect to refuse Third Party cookies such as Sojern’s, or delete cookies altogether. However, should you block or delete Third Party cookies such as Sojern’s by adjusting your web browser settings, you will continue to receive online advertisements but those advertisements may be less relevant to you.
For mobile users, you also have numerous controls in your Operating System that enable you to choose whether to allow cookies, or share your advertising ID with companies like Sojern. For some information on controlling your mobile choices, click here.
In addition to browser or mobile controls, you may choose to opt-out directly from Sojern and many other advertising services through industry self-regulatory efforts. If you wish to opt-out of web-based ads (not specifically for mobile users) delivered through the Sojern Platform, you may do so by clicking here. Please note this only opts you out of behaviorally targeted ads through the Sojern Platform and does not opt you out of being served any travel-related advertising from other advertising services. When you opt out, we will place a cookie on your browser instructing us not to deliver a behaviorally targeted ad. Please note that there may be a delay in the ability to update the information and honor your choice, and if you delete your cookies, your opt-out request will no longer be recognized or honored.
In addition, Sojern may receive signals from advertising service providers or Data Partners that request we limit the tracking of ads, independent from the process of creating or appending data to our traveler profiles. Should we receive these signals, we will honor the request to cease tracking and will limit the use of any data collected to research and development purposes only.
You may also choose to opt-out of industry-wide Interest-Based Advertising (aka; online behavioral advertising) by clicking through to the regional Digital Advertising Alliance in your location:
To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA mobile app:
Your Choices with Sojern’s Service Providers
Sojern works in conjunction with numerous service providers who may also offer choices to opt-out of their advertising services. Please click below to learn more about your choices with these key Sojern service providers:
In addition, Sojern works with mobile attribution providers who are associated with publishers that utilize Sojern for various mobile advertising services. In order to opt-out of data collection through these services, please refer to the choices listed in the privacy policies of the publishers you visit.
To enable users to easily manage personal information we collect, Sojern has created a “Right of Access and Right to Erasure” tool, available here. If you wish to learn what information Sojern has about you, and/or to exercise your right to delete this information, we encourage you to use this tool.
You may also submit a request for, Sojern to provide you with information about whether we hold any of your personal information. To make a personal information request, please refer to the Contacting Sojern section below, and we will respond to your request within a reasonable timeframe. Please note that we reserve the right to verify your identity and country of residency to determine if such access is required under your local laws. Please also note that because Sojern Products do not collect identifying information from End Users such as name or email address, we may need information from you such as your mobile advertising ID or cookie ID to locate the particular data we may have about you.
If you have provided us personal information as a Client, or your personal information has been provided by a Client’s representative, we will inform you if we hold any of your personal information upon your request. You may access, correct, or request deletion of your personal information by logging in to your Sojern account or by contacting us at email@example.com. We will respond to your request within a reasonable timeframe.
You may sign up to receive emails, newsletters or other communications from us. If you would like to discontinue receiving these communications, you may update your email preferences by using the “unsubscribe” link found in emails we send to you, via your member profile on our website, or by contacting us at firstname.lastname@example.org.
At the current time, Sojern retains collected data for as long as it is necessary to maintain the efficacy of the Sojern Products, provide our Clients services, and as needed to comply with our legal obligations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, and enforce our agreements.
The security of your information is important to us. Sojern utilizes standard frameworks, best practices, and programming language paradigms to prevent access to data stored in the Sojern Platform. Sojern employs strict controls around employee access to the Sojern Platform, including real-time monitoring through a third-party IT management vendor. Sojern maintains a comprehensive data access grid based on role and associated permissions to all tools and data stores within our data warehouse. Access is granted based on explicit business need and use cases which warrant access. If you have any questions about the security of your information, please contact us as described below.
The Sojern Platform is hosted through a cloud architecture provided by a Third Party, Google, Inc. Currently, the architecture hosted by Google in connection with providing the Sojern Platform and associated services is located in various locations around the world. Google’s data centers have access system controls in place, including a layered security model with numerous safeguards. Further information about security provided by Google is available from the Google Security Web site here.
Sojern Products are designed for a global market. Our Data Partners and Clients operate media properties around the world, and the Sojern Platform utilizes data collected from many countries. As noted, this data is stored within Google’s cloud hosting infrastructure in various locations around the world, including in the United States.
Sojern participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
Sojern is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Sojern complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Sojern is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions more fully described on the Privacy Shield website you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Our Services are not directed to children under 13 (or other minimum age as required by local law) and we do not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible and terminate the child’s account.
Do Not Track
Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites visited by the user about the user’s browser DNT preference setting. Sojern does not currently commit to responding to browsers’ DNT signals with respect to the Site. For more information on “do not track”, please visit www.allaboutdnt.com.
“Shine the Light” Law
Pursuant to California Civil Code Section 1798.83(c)(2), Sojern does not share Personal Information with Third-Parties for their direct marketing purposes unless you affirmatively agree to such disclosure. If we do share Personal Information with Third-Parties for their direct marketing purposes and you authorize us to include your information, we will only share that information in connection with that specific promotion. To prevent disclosure of your Personal Information for use in direct marketing by a Third Party, do not opt in to such use when you provide Personal Information on our Site or the service. If you later decide that you do not want that third party to use your Personal Information, you will need to contact the Third Party directly.
California customers can receive more information about our compliance with this law or to make a request under California Civil Code Section 1798.83 by sending us an email at firstname.lastname@example.org, or by writing to us as set forth in “Contacting Sojern” below.
If you have questions or concerns about our collection, use, or disclosure of your information, or how to lodge a complaint with the appropriate authority, please email us at email@example.com, or please write to us at:
Attention: Privacy Officer
255 California Street
San Francisco, CA 94111
If Sojern does not adequately respond, or if you have an unresolved privacy or data use 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.