Website Privacy Policy

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.

This Privacy Policy applies solely to the Personal Information we collect and use on our website, or websites that link to this Privacy Policy, including (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

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


Quick Reference:


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 Wi-Fi 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”.


We acquire, hold, use, and process information, including Personal Information, collected through our Site or from Third-Party sources for a variety of business purposes, including as described in this Privacy Policy above under “Types of Information We Collect”. In addition, we may use the information, including Personal Information, we collect for the following purposes:

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:

  • Generally manage individual information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of our Site;
  • Contact you to answer requests for customer support or technical support;
  • Allow you to register for events.

Administrative Purposes. We may use personal information about you for administrative purposes, including to:

  • Measure interest in our Site;
  • Develop new products and features;
  • Ensure internal quality control;
  • Verify individual identity;
  • Communicate about individual accounts and activities on our Site, and, in our discretion, changes to any Sojern policy;
  • Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms.

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:

  • To tailor content, advertisements, and offers; To notify you about offers, products, and services that may be of interest to you; To provide services to you and our sponsors; For other purposes disclosed at the time you provide personal information; or Otherwise with your consent.

You may contact us at any time to opt out of the use of your personal information for marketing purposes, as further described in Data Security and Retention.

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.

Services via Mobile Devices. From time to time, Sojern may provide services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of our Site may require that users log in with an account. In such cases, information about use of mobile versions of the Site may be associated with accounts. In addition, we may enable individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit personal information to Sojern to enable individuals to access accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.

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.


We don’t sell or share your Personal Information to Third-Parties for their promotional purposes. We may share your 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.

Business Partners
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.

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 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, as permitted by law and/or contract. In such event, Sojern will endeavor to direct 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, as permitted by law and/or contract. In such event, Sojern will endeavor to direct the Third-Party to agree to use your Personal Information in a way that is consistent with this Privacy Policy. 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.


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.

We partner with third parties to manage our advertising on other sites. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here or if located in the European Union click here. Please note you will continue to receive generic ads.


You may request access to your Personal Information collected by Sojern. Where otherwise permitted by applicable law, you may email us at the relevant email address identified in the “Contacting Sojern” Section of this Privacy Policy to request access to, receive (port), seek rectification, or require erasure of your Personal Information. For all such requests, please include your full name, email address associated with your account, and a detailed description of your request. Such requests will be processed in line with local laws. When updating your Personal Information, we may ask you to verify your identity 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.

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 ( 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 fulfill the purposes outlined in this Privacy Policy, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, unless a longer retention period is required or permitted by law.


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. For your reference, “Process” or “Processed” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

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. (

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 (, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

By choosing to visit the Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the state of Nebraska and the adjudication of any disputes arising in connection with Sojern or the Site will be in accordance with the Terms.


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 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 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.


The Site may contain links to websites and services provided by Third-Parties (e.g. social media buttons) and other websites may reference or link to our Site. 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. These other domains and websites are not controlled by us, and 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.


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.

If you already use these social media platforms, their cookies may be set on your device when using our Site or other services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes. 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.


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 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

“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, or by writing to us as set forth in “Contacting Sojern” below.


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. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the services after the updated Privacy Policy is posted on the Site. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the services. Before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out.

If we make any material changes to this Privacy Policy, we’ll provide prominent notice by posting a notice on the Site and/or notifying you by email (using the email address you provided) before the changes are made, 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.


If you have questions or concerns about our collection, use, or disclosure of your Personal Information, or how to lodge a complaint with the appropriate authority, please email us at, or please write to us at:

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