Last Updated: October 15, 2018
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, railway, and tourism categories.
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.
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
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.
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
To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for products, services, or information, including information about potential or future services, including to:
Administrative Purposes. We may use personal information about you for administrative purposes, including to:
Marketing Sojern Products and Services. We may use Personal Information to provide you with materials about offers, products, and services that may be of interest, including new content or services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services, develop new products and services, or optimize the Site. From time to time, We may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our services, various types of communications, advertising campaigns, and/or promotional activities. If you participate in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Sojern’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Data Security and Retention.
Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Site, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Sojern and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
To learn more about how we use your information for personalization and tracking, including advertising, please see visit Online Tracking Technologies and Advertising Policy.
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.
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.
We may share your personal information with Third-Parties to provide services on our behalf. 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.
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.
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 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
Change of Control
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to our processing of your Personal Information, you may withdraw that consent at any time and opt out of further processing by contacting us as described in the “Contacting Sojern” section below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Site and/or information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.
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.
Although Sojern makes good faith efforts to provide you with access to, change, or delete your Personal Information, there may be circumstances in which we are unable to, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary, where the request is unreasonably repetitive, or requires disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice). 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. If Sojern determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Sojern will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
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.
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. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. 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.
EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield
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. (https://www.privacyshield.gov)
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 (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
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 future marketing emails at any time by clicking the “Unsubscribe” link at the bottom of these emails, or sending an email to firstname.lastname@example.org. You can further indicate your preferences by contacting us using the information in the “Contacting Sojern” section below. We will your process your request within a reasonable time after receipt. 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.
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 email@example.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.
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
Our Site may use social media features, such as the Facebook ‘like’ button (“Social Media Features”) that contain links and interactive features with various social media platforms. 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.
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 firstname.lastname@example.org. 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.
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.
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.
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.
255 California Street
San Francisco, CA 94111