Sojern Privacy Center

U.S. State Privacy Notice

Last Updated July 28, 2026

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.

Personal Information Collection, Disclosure, and Sale

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.

Category Collected Disclosed Sold/Shared
A. Identifiers
Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, device identifiers, cookie IDs, mobile advertising IDs (MAIDs), or other similar identifiers.

Processing purposes: Providing our Services, communicating, marketing and advertising, facilitating payments, job applications, enabling transactions, deidentification and aggregation, safety issues, compliance, auditing interactions, fraud and incident prevention, research, improving our Services.
Yes Yes Yes
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
Examples: Name, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other financial information.

Processing purposes: Providing our Services, communicating, marketing and advertising, facilitating payments, job applications, enabling transactions, safety issues, compliance, fraud and incident prevention, improving our Services.
Yes Yes No
C. Characteristics of Protected Classifications under State or Federal Law
Examples: Race or ethnicity, veteran status (collected from job applicants on a voluntary basis for diversity monitoring).

Processing purposes: Job applications.
Yes No No
D. Commercial Information
Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Processing purposes: Marketing and advertising, improving our Services, research, auditing interactions.
Yes Yes Yes
E. Biometric Information
Examples: Physiological, biological, or behavioral characteristics that can be used to establish individual identity.
No N/A N/A
F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement (including cookie data, URLs, referrer information, and clicks/web visits).

Processing purposes: Marketing and advertising, providing our Services, improving our Services, research, auditing interactions, debugging.
Yes Yes Yes
G. Geolocation Data
Examples: General physical location (e.g., inferred from IP address).

Processing purposes: Marketing and advertising, improving our Services, research.
Yes Yes Yes
H. Sensory Information
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
No N/A N/A
I. Professional or Employment-Related Information
Examples: Job application or resume information, past and current job history, references, and job performance information.

Processing purposes: Job applications.
Yes No No
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
No N/A N/A
K. Inferences Drawn from Personal Information
Examples: Consumer profiles reflecting a consumer's preferences, characteristics, predispositions, behavior, and attitudes (e.g., audience segments and in-market travel interests).

Processing purposes: Marketing and advertising, improving our Services, research.
Yes Yes Yes
L. Sensitive Personal Information (Identifiers)
Examples: Government identification documents (collected from job applicants).

Processing purposes: Job applications, compliance.
Yes No No
M. Sensitive Personal Information (Log-In and Financial Information)
Examples: Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

Processing purposes: Providing Services, enabling transactions, facilitating payments.
Yes No No
N. Sensitive Personal Information (Precise Geolocation)
Examples: Geolocation data used to locate a consumer within a geographic area equal to or less than the area of a circle with a radius of 1,850 feet.
No N/A N/A
O. Sensitive Personal Information (Group Membership)
Examples: Racial or ethnic origin, religious or philosophical beliefs, or union membership.

Processing purposes: Job applications (racial or ethnic origin, on a voluntary basis for diversity monitoring).
Yes No No
P. Sensitive Personal Information (Contents of Communications)
Examples: The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication.
No N/A N/A
Q. Sensitive Personal Information (Genetic Data) No N/A N/A
R. Sensitive Personal Information (Identifying Biometric Information) No N/A N/A
S. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Health) No N/A N/A
T. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Sex Life or Sexual Orientation) No N/A N/A

Use of Personal Information

We collect your Personal Information for the following specific business and commercial purposes:

  • Providing Services: Providing, maintaining, and delivering our Services, including helping businesses identify and advertise to in-market travelers, optimizing advertising campaigns across channels and devices, and delivering insights.
  • Communicating: Communicating with you, providing updates and information relating to our Services, responding to comments and questions, and otherwise providing customer support.
  • Marketing and Advertising: Marketing and advertising purposes, including online behavioral and cross-context behavioral advertising, developing and delivering promotional and advertising materials, and creating audience segments.
  • Facilitating Payments: Facilitating transactions and payments.
  • Deidentification and Aggregation: Deidentifying and aggregating information collected through our Services and using it for lawful purposes.
  • Job Applications: Processing your job application and recruiting for open positions.
  • Safety Issues: Maintaining service performance and security and responding to trust and safety issues that may arise.
  • Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  • Auditing Interactions: Auditing related to your interaction with our Services and concurrent transactions.
  • Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging: Debugging to identify and repair errors that impair existing intended functionality.
  • Research: Undertaking internal research for technological development and demonstration.
  • Contracting Vendors: Contracting with vendors and service providers to perform services on our behalf.
  • Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our Services, and to improve, upgrade, or enhance our Services.
  • Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
  • Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Collection of Personal Information

We collect Personal Information from the following categories of sources:

  • You/Your Devices: You or your devices directly.
  • Clients and Partners: Our clients and partners, including via pixels, tags, and SDKs deployed on their online properties, server to server integrations and customer relationship management (CRM) data and audience data they provide.
  • Advertising Providers.
  • Analytics Providers.
  • Social Networks.
  • Data Providers / Resellers: Third-party sources of business-to-business leads, contact information, and audience data.
  • Recruitment Sources: Recruitment agencies and professional profiles posted online (for job applicants).
  • Public: Publicly accessible sources.

Disclosure of Personal Information

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:

  • Advertising Partners: 
    • Personal Information we disclosed: Identifiers; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
  • Analytics Providers: 
    • Personal Information we disclosed: Identifiers; Internet or Other Electronic Network Activity Information.
  • Social Media / Social Networks: 
    • Personal Information we disclosed: Identifiers; Internet or Other Electronic Network Activity Information.
  • Affiliates and Subsidiaries: 
    • Personal Information we disclosed: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information; Professional or Employment-Related Information.
  • Vendors and Service Providers: 
    • Personal Information we disclosed: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information; Professional or Employment-Related Information.
  • Third Parties as Legally Required: 
    • Personal Information we disclosed: As required by law and similar disclosures.

Selling and Sharing of Personal Information

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:

  • Advertising Partners: 
    • Personal Information we sold or shared: Identifiers; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
  • Analytics Providers: 
    • Personal Information we sold or shared: Identifiers; Internet or Other Electronic Network Activity Information.
  • Social Networks: 
    • Personal Information we sold or shared: Identifiers; Internet or Other Electronic Network Activity Information.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age. 

Your U.S. State Privacy Rights

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:

  • Right to Know / Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, shared, or disclosed by us; (2) purposes for which categories of Personal Information are collected, sold, or shared by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties to whom we disclosed, sold, or shared Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
  • Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
  • Right to Correct. You may submit a verifiable request that we correct inaccurate Personal Information that we maintain about you.
  • Right to Data Portability. You have the right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
  • Right to Opt Out of Sale/Share and Targeted Advertising. You may opt out of the sale or sharing (for cross-context behavioral advertising purposes) of your Personal Information and of the processing of your Personal Information for targeted advertising. You may exercise this right by visiting our Privacy Center, by using the “Your Privacy Choices” link in our website footer, or by broadcasting an opt-out preference signal as described below.
  • Right to Opt Out of Profiling. In some circumstances, you may opt out of the processing of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Limit Use and Disclosure of Sensitive Personal Information. In some circumstances, you may limit our use and disclosure of your Sensitive Personal Information. 
  • Right of No Retaliation / Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of your privacy rights, subject to certain limitations, including if you are an employee, applicant, or independent contractor of our business.
  • Right to Appeal. If we decline to take action on your request, you may appeal that decision by sending an email to the address in the Contact Information section below.

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.

Additional Disclosures

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.

Request Type Received Complied (in whole or part) Denied Mean/Median Days
Requests to Know/Access [#] [#] [#] [#]
Requests to Delete 59 59 0 1
Requests to Correct [#] [#] [#] [#]
Requests to Opt-Out of Sale/Sharing 284,690 284,690 0 1
Requests to Limit Use of Sensitive Personal Information NA NA NA NA

Contact Information

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