Website Privacy Policy (www.sojern.com)

Last Updated: February 17, 2017

Sojern, Inc. (“Sojern,” “We,” “Us,” and “Our”) is a data-driven traveler 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, and tourism categories.

This Privacy Policy applies solely to the information we collect and use on our website, or websites that link to this Privacy Policy, including www.sojern.com (collectively referred to as the “Site”), and does not apply to our various advertising related products (“Sojern Products). Please see our Product Privacy Policy for information on our privacy practices as they relate to our Sojern Products.

Our Privacy Policy explains:

Our Privacy Policy is designed to provide transparency into our privacy practices and principles. We’ve tried to keep it as simple as possible, but if you’re not familiar with terms like cookies, IP addresses, pixel tags and browsers, then read about these key terms first. Your privacy is important to us at Sojern and a responsibility we take seriously, so we encourage you to review our Privacy Policy. If you have questions about our privacy practices, please contact us at sojernprivacy@sojern.com.

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.

Quick Reference:

TYPES OF INFORMATION WE COLLECT

We collect two types of information about you: (1) information that you may choose to voluntarily provide us while using the Site (described below under “Information You Provide to Us” and (2) information collected automatically as result of your use of the Site or service (described below under “Information Collected Automatically”). We may also receive information about you from third-party sources (as described below under “Information Received from Third-Party Sources”).

Information You Provide to Us

You may choose to voluntarily provide certain personal information to us — such as name, telephone number or email address in order to access certain features of our Site or request information from us. For example, the Site allows you to request product and service information from Sojern; register for special offers, events, webinars, workshops, or demonstrations; participate in surveys and contests; download research papers, eBooks, and marketing content; subscribe to newsletters; and to submit an application for employment. To support these activities, Sojern will ask for information about you and / or the company for which you work.

When you send us a message using the Contact Us page or via email, we retain the content of the message, your email address, and any information you provide to us such as your name, your company, experience with our service, your contact preferences, and the response we send back to you. This helps us manage any follow-up questions you may have, measure how effectively we address your concerns and improve the Site and the service. Any information retained would be used to assure the delivery of the services or information you requested, to optimize your experience and enhance the quality of the time you spend with us online, and to tailor personalized communications or promotions to you in the future.

Information Collected Automatically

Like most web-based services, we (or our service providers) may automatically collect information from your browser or your device when you use the Site. For example, this could include the frequency and duration of your visits to the Site (similar to TV ratings that indicate how many people watched a particular show). If you visit the Site on different devices, we may link the information we collect from those different devices to help us provide a consistent service across your different devices or to provide you relevant Sojern advertisements. If we do combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy.

The technologies and information we automatically collect include:

Please read our Online Tracking Technologies and Advertising Policy for more details, including how to remove or modify your cookie settings at your preference and a list of the online tracking technologies we use.

  • Device information
    We may collect device-specific information such as your operating system, hardware version, device settings, file and software names and types, and unique device identifiers. This helps us measure how the Site is performing and improve the Site for you on your particular device.
  • Location information
    When you use our Site, we may collect and process information about your geographic location, for example through IP address, GPS, Bluetooth, or WiFi signals. We collect coarse (i.e., city-level) location data.
  • Server Log Information
    Like most online services, when you use our Site, we automatically collect and store certain information in our server log files. Examples include things like:

This information helps us make decisions about what we should work on next – for example, by showing which features are most (or least) popular. We may use your IP address and share it with third parties to help diagnose problems with our servers, for security purposes, to manage the Site, to enhance the Site and services based on usage pattern data, for analytics and for advertising.

Information Received from Third-Party Sources

We may also obtain information, including personal information, from third-party sources to update or supplement the information you provided or we collected automatically. Local law may require you authorize the third-party to share your information with us before we can acquire it. This may include aggregated anonymous information or certain personal information that may be provided to us. If we receive personal information from third parties we will handle it in accordance with this Privacy Policy. If we directly combine information we receive from other third parties with personal information that we collect on the Site, we will treat the combined information as personal information and handle it in accordance with this Privacy Policy. Additionally, we may use any aggregated anonymous information received by third parties as set forth below under the heading “Aggregated Information and Non-Identifying Information”.

HOW WE USE THE INFORMATION WE COLLECT

We use information, including personal information, collected through our Site for the purposes described in this Privacy Policy, including as set forth above under “Information Collected Automatically”. In addition, we may use the information, including personal information, we collect for the following purposes:

To learn more about how we use your information for personalization and tracking, including advertising, please see visit Online Tracking Technologies and Advertising Policy.

SHARING YOUR INFORMATION

We don’t sell your personal information to third parties for their promotional purposes. We do not share personal information with third parties except for the limited circumstances set forth in this Privacy Policy, including:

Third-Party Integrations on Our Site:
When you use third-party apps, websites or other services that use, or are integrated with, our Site, they may receive information about what you post or share. For example, when you share via Facebook or Twitter, these services receive the information that you share through this functionality, and information that you are sharing from our Site. Information collected by these apps, websites or integrated services is subject to their own terms and policies.

Service Providers: We do work with vendors, service providers, and other partners to help us provide the Site and other services by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. Additionally, we may also share information with social networking and other websites, applications or partners, for marketing and advertising our products or services on those websites or applications. Generally, these partners and service providers do not have the right to use your personal information we share with them beyond what is necessary to assist us. Additionally, these partners and service providers must adhere to confidentiality and security obligations in a way that is consistent with this Privacy Policy.

Business Partners: From time to time, Sojern may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from Sojern, we may share information collected in connection with your purchase or expression of interest with our joint promotion partner(s). Sojern does not control our business partners’ use of the information we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service. Sojern does not share information with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Sojern event and allow Sojern or any of its designees or partners to scan your attendee badge. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Sojern events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.

Analytics Services: We use analytics services, including mobile analytics, to help us understand and improve how the Site and our service is being used. These services may collect, store and use information in order to help us understand things like how often you use the Site, the events that occur within the Site, usage, performance data, and from where the application was downloaded.

Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information publicly, including with users, partners or the press in order to, for example, demonstrate how Sojern is used, spot industry trends, or to provide marketing materials for Sojern. Any aggregated information shared this way will not contain any personal information.

Legal Requirements: 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 personal 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.

Sharing with Sojern Companies: Over time, Sojern may grow and reorganize. We may share your information, including personal 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 personal information in a way that is consistent with this Privacy Policy.

Change of Control: In the event that all or a portion of Sojern or its assets are acquired by or merged with a third party, or in any other situation where personal information that we have collected from users would be one of the assets transferred to or acquired by that third party, we may disclose, share or transfer the information. This Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, or by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, you may request its deletion from the company. We may also make information, including personal information, available to a potential investor or purchaser (as their advisors) in advance of any such transaction completion.

With your consent: Other than the cases above, we won’t disclose your personal information for any purpose unless you consent to it. Additionally, as discussed above, we will never sell your personal information to advertisers or other third parties

ACCESS AND MANAGING YOUR PERSONAL INFORMATION

You have a right to request access to your personal information collected by Sojern by emailing us at the relevant email address identified in the “Contact Us” Section of this Privacy Policy. You may, at any time, update, correct, or delete certain personal information that you have provided to us by contacting us as set forth below in the “Contacting Us” section. When updating your personal information, we may ask you to verify your identify before we can act on your request. You may also exercise your control or choices with the communications we send you as set forth in “Communications from Sojern” section below.

Please be aware that even if you update or remove personal information that you have provided to us, your personal information may be retained in our backup files and archives for a reasonable period of time for legal purposes or for so long as is necessary in light of the purposes for which such records were collected or legitimately further processed.

We may reject requests for access, change or deletion that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). In some cases, we won’t be able to guarantee complete access due to legal restrictions – for example, you will not be allowed to access files that contain information about other users or information that is confidential to us.

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

DATA SECURITY AND RETENTION

The security of your personal information is important to us. To prevent unauthorized access, disclosure, or improper use of your information, and to maintain data accuracy, we’ve established physical, technical, and administrative safeguards to protect the personal information we collect. Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time.

If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (www.sojern.com) or elsewhere on the Site, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

We will retain your personal information for the length of time needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

INTERNATIONAL USERS

This Site is hosted and operated in the United States. If you access or use the Site from the European Union, or any other region, the personal information you submit to our Site will be transferred to and stored in the United States and other countries to be processed by us so we can provide this Site to you as set forth in this Privacy Policy and the Terms of Use Agreement.

By using the Site, you consent to the transfer of your personal information outside your home jurisdiction, including to the United States, and to the storage of your personal information in the United States, for the purpose of hosting, using and processing the personal information in accordance with this Privacy Policy. You further acknowledge that these countries may not have the same data protection laws as the country from which you provided your personal information, and that Sojern may be compelled to disclose your personal information to U.S. authorities. You have the right to withdraw your consent at any time by contacting us.

COMMUNICATIONS FROM SOJERN

If you registered on Sojern, provided an email or phone number to us, or otherwise opted-in to receive communications from us, we may send you messages and updates regarding your account, including privacy and security notices, updates regarding the service, and information regarding products, features or services from Sojern. These communication methods may include, but are not limited to, email, postal mail, social media communications, telephone calls, and push notifications. If you have an account with us, we’ll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business. We may receive a confirmation when you open an email from us if your device supports it. We use this confirmation to help us understand which emails are most interesting and helpful.

You can always unsubscribe from receiving any of our marketing emails at any time by clicking the “Unsubscribe” link at the bottom of these emails, or sending an email to sojernprivacy@sojern.com You can further indicate your preferences by contacting us using the information in the “Contacting Sojern” section below. Please note that opting-out of marketing communications does not affect your receipt of business communications that are important to your interaction with Sojern, such as support/service communications, security updates, or account management communications. You may not opt-out of receiving these communications.

THIRD-PARTY SERVICES

The Site may contain links to websites and services provided by third parties (e.g. social media buttons). Any personal information you provide on third-party websites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. This Privacy Policy does not apply to these websites or services. The fact that we link to a website is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We are not responsible for the content or privacy and security practices and policies of third-party websites or services. We encourage you to learn about third parties’ privacy and security policies before providing them with personal information.

SOCIAL MEDIA FEATURES

Our Site may use social media features, such as the Facebook ‘like’ button (“Social Media Features”). These features may collect your IP address and which page you are visiting our Site, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on our Site to a profile page of yours that is provided by a third- party Social Media network in order to share with others within your network. Social Media Features are either hosted by a third- party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

CHILDREN

This Site is not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personal information. Additionally, we do not knowingly collect or maintain personal information from anyone under the age of 13. If we become aware that a child under 13 has provided us with personal information, then we will delete this information from our files. If you are the parent or legal guardian of a child under 13 who you believe has provided personal information to Sojern, please send an email to Sojern at sojernprivacy@sojern.com or contact us as set forth in the “Contacting Sojern” section below to have that child’s information deleted.

ONLINE SURVEYS AND FEEDBACK

We like feedback, which means we may conduct online surveys to solicit your opinions and comments. Participation in these surveys is of course optional. If you choose to participate, the information you provide will be aggregated with information from other users to make improvements to the user experience and develop appealing content, features, and promotions. Unless otherwise noted in a survey, your participation will remain anonymous.

You can also ask us questions and share comments or suggestions with us. Your questions, comments, and suggestions may not be kept confidential. We may use your questions, comments, and suggestions to improve the Site and our service, but we will have no obligation to compensate you for any such contributions. If you offer your name and address when you contact us, we’ll be happy to respond directly to you.

TESTIMONIALS

With your consent we may post your testimonial along with your name, photo and/or video. If you wish to request the removal of your testimonial, you may contact us using the information in the “Contacting Sojern” section set forth below.

CALIFORNIA PRIVACY DISCLOSURES

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.org.

“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 sojernprivacy@sojern.com, or by writing to us as set forth in “Contacting Sojern” below:

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. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Site and/or notifying you by email (using the email address you provided), 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 personal information, please email us at sojernprivacy@sojern.com, or please write to us at:

Privacy
Sojern, Inc.
255 California Street
Suite 1000
San Francisco, CA 94111

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