This U.S. State Privacy Notice (this “Notice”) supplements the information and disclosures contained in our Privacy Policy. It applies to the residents of certain U.S. states that have enacted comprehensive privacy laws that apply to our operations (the “U.S. State Privacy Laws”) and explains how we collect and process information about you as a “business” or “controller” and how you can exercise your privacy rights under those U.S. State Privacy Laws. This Notice does not apply to Personal Information that Sojern processes on behalf of business customers as a processor or service provider, including in connection with our Guest Experience Solutions product.
For the purposes of this Notice, “Personal Information” means “personal information,” “personal data,” or any analogous term under applicable U.S. state privacy laws (“U.S. State Privacy Laws”). Personal Information does not include information that is: publicly available or lawfully obtained, truthful information that is a matter of public concern; deidentified or aggregated; or otherwise excluded from the scope of applicable U.S. State Privacy Laws.
The chart below provides the categories of Personal Information and “Sensitive Personal Information” (as defined by the California Consumer Privacy Act) we have collected, disclosed for a business purpose, or sold or “shared” (for cross-context behavioral advertising purposes) in the preceding twelve months since this Notice was last updated. Because Sojern operates in the programmatic advertising ecosystem, our disclosure of pseudonymous Personal Information (such as cookie IDs, mobile advertising IDs, and IP addresses) to ad exchanges, ad networks, and other participants in that ecosystem may constitute a “sale” or “share” of Personal Information under U.S. State Privacy Laws, even absent an exchange of money. The examples provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
We collect your Personal Information for the following specific business and commercial purposes:
We collect Personal Information from the following categories of sources:
In the preceding twelve months since this Notice was last updated, we disclosed Personal Information to the following categories of third parties for the purposes of providing our Services, marketing and advertising, auditing interactions, contracting vendors, improving our Services, fraud and incident prevention, and compliance:
Sojern is registered as a data broker with the California Privacy Protection Agency. To learn how to exercise your rights, including your right to opt out of the sale or sharing of your Personal Information, see “Your U.S. State Privacy Rights” below.
In the preceding twelve months since this Notice was last updated, we sold or “shared” (for cross-context behavioral advertising purposes) Personal Information to the following categories of third parties for the purposes of marketing and advertising:
We do not knowingly sell or share the Personal Information of consumers under 16 years of age.
If you are a U.S. resident of a state with an applicable U.S. State Privacy Law, you may exercise the following rights, subject to certain exceptions and limitations:
Verification. Requests to know, delete, or correct Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant U.S. State Privacy Law requirements, limitations, and regulations. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information where permitted by law, and we reserve the right to confirm your state of residency.
Submit Requests. To exercise your rights, please visit the Privacy Center or send an email to the address in the Contact Information section below.
Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a U.S. resident, please provide us with written authorization signed by the resident (or a valid power of attorney), and we will contact you and the resident with further steps required to verify the resident’s identity and your authority to act.
Opt-Out Preference Signals. You may also opt out of the sale or sharing (for cross-context behavioral advertising purposes) of your Personal Information and of processing for targeted advertising by turning on the Global Privacy Control (GPC) in participating browser systems. You will need to turn the GPC on for each browser you use. To learn more about the GPC, visit the Global Privacy Control website.
Number of Privacy Requests. In the preceding twelve months, we received, complied with (in whole or in part), and denied consumer privacy requests as set forth below. Requests may be denied where we could not verify the requester’s identity, where an exception under applicable law applied, or where no responsive information was found.
If you have any questions, comments, or concerns about this Notice or our processing activities, please email us at sojernprivacy@sojern.com or write to us at:
Sojern, Inc.
Attention: Privacy
545 Market Street, Floor 4
San Francisco, CA 94105