Product Privacy Policy

Last Updated: May 17, 2017

About Sojern

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”).

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies solely to the information we collect and use in connection with our Sojern Products, including the information we receive from the websites or media properties of our Data Partners and Clients (collectively, the “Third Party Sites”), and does not apply to information we collect and use on our corporate website, located at www.sojern.com. Please see our Website Privacy Policy for information on our privacy practices as they relate to our Sojern website. Additionally, the collection of information by our Data Partners and Clients and their use and disclosure of such information is subject to their own individual privacy policies.

SOJERN’S INDUSTRY CERTIFICATIONS, COMMITMENTS AND ADHERENCE

Sojern supports initiatives of greater transparency and control for users and participates in the following industry self-regulatory efforts:

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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.

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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.

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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

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KEY TERMS

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 PLATFORM OVERVIEW

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 acts as a service provider on behalf of our Clients who purchase our products and services for their use. We do not have a direct relationship with consumers or other end users, as we work in coordination with advertising delivery platforms and advertisers to help facilitate targeted advertisements. This Privacy Policy describes our collection and use of various types of information we utilize on behalf of these Clients and Data Partners to assist them in their disclosure obligations to their End Users on the Client’s or Data Partner’s website or mobile application, as applicable.

TYPES OF INFORMATION WE COLLECT

Sojern Products do not intentionally collect any information 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 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, then Sojern will randomize this information to make it unreasonable for either Sojern or our travel partner 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, 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, WiFi status, GPS, and other attributes.

Location-Based Information

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, Wifi, Bluetooth, or mobile device GPS. See below in the ‘Your Choices’ section for more information on restricting access to this type of information.

Cross-Device Collection

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.

HOW WE USE THE INFORMATION WE COLLECT

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.

Cross-Device Tracking

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.

Cookie Lifespan

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. Please note that at the current time, Sojern retains collected data for as long as it is necessary to maintain the efficacy of our products, and as needed to comply with our legal obligations, resolve disputes and enforce our agreements.

SHARING YOUR INFORMATION

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.

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 disclose or share any, and all, information associated with Sojern Products in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where information may be disclosed or transferred as one of the business assets of Sojern. In the event of such a change of control of Sojern, all data will remain subject to the terms of the then-applicable privacy policy. Prior to such a change of control, Sojern will provide notice of a change on our website, and you will be given an opportunity to review the terms and potentially opt-out of any material changes prior to the control change taking place.

Over time, Sojern may grow and reorganize. We may share your information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your information in a way that is consistent with this Privacy Policy.

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.

In any other case not mentioned in this policy, we will provide you with advance notice should such a change be considered ‘material’, and if necessary, request your consent to sharing this new type of information with other parties.  We may also disclose your information to any other third party with your prior consent.

As noted, we work with numerous vendors, service providers, and other partners to help us provide Sojern Products and services. We share or provide information (including personal information if deemed so by local laws) to them to help perform necessary business functions. Generally, these service providers do not have the right to use your information we share with them beyond what is necessary to assist us, and are only authorized to use your unique user information as necessary to provide these services to us. Additionally, these service providers must adhere to confidentiality and security obligations in a way that is consistent with this Privacy Policy. In the Your Choices section below, we’ve identified some key service providers that you may choose to control some of your choices with regards to this type of data sharing.

YOUR CHOICES

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:

  • Google’s Doubleclick Bid Manager (DBM) facilitates the ad selection and delivery of our Clients’ advertisements to both web and mobile users (including some mobile applications). Learn more here.
  • Tapad is a mobile solutions provider that helps facilitate an ID synchronization with our web-based cookies. Learn more here.

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.

ACCESS AND MANAGING PERSONAL INFORMATION

As noted, Sojern Products do not intentionally collect or store any information that would personally identify you in the real world such as name, phone, email or postal address. Therefore, it is generally not feasible for us to provide you with access to, or the ability to manage, your personal information. However, as some information may be considered personal under country-specific laws, we will make every effort to provide you with the ability to access and manage your information should we be required to comply with such laws. To make a personal information request, please refer to the Contacting Sojern section below. 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.

DATA SECURITY

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 business need and is never broadly granted without 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.

INTERNATIONAL USERS

Sojern’s 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 the United States, and we contractually require our Data Partners and Clients to acquire consent for such a transfer to the United States should local law require such consent. Should you wish to withdraw consent, you can do so by opting out of Sojern cookies, or using the other tools provided to you in the Your Choices section above.

CHILDREN

We do not knowingly collect or maintain personal information from End Users under the age of 13. If we become aware that a child under 13 has provided us with any information that would require compliance with the Children’s Online Privacy Protection Act (COPPA), then we will delete this information from our databases.

CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may revise our Privacy Policy from time to time. You can see when the last update was by looking at the “Last Updated” date at the top of this page. If we make any material changes, we’ll provide prominent notice by posting a notice on the Site so you can review and make sure you know about them. We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use, and disclosure of personal information through the Site.

CONTACTING SOJERN

If you have questions or concerns about our collection, use, or disclosure of your information, please email us at sojernprivacy@sojern.com, or please write to us at:

Sojern, Inc.
Attention: Privacy Officer
118 2nd Street, Third Floor
San Francisco, CA 94105

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.

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