This Guest Experience Solutions Product Privacy Policy describes the privacy practices of Sojern, Inc., and its subsidiaries ("Sojern," "we", "us" or "our") with regards to our Guest Experience Solutions product ("GES", or the "Service.") For information regarding our privacy practices in the context of our advertising services, business representatives with whom we interact, our website, or our recruitment activities, please see the Sojern Privacy Policy.
In the context of providing the Service, we operate as a “processor”, “service provider”, or equivalent role under relevant privacy law. This means that we provide the Service to business hospitality customers (“Customers”), who may use it to interact with consumers (“Guests”). These Customers determine how personal information is stored and used within the Service. As such, the collection, storage, use and sharing of Guest personal information by Customers is subject to their respective privacy policies and practices. We cannot control, and are not responsible for, the privacy practices of these Customers. If you have questions about the privacy or security practices of any Customer, please refer to the applicable Customer’s privacy or security notices.
When interacting with the Service, Guests may provide personal information to Customers which is processed via the Service, which may include:
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as third-party travel booking and review websites.
Automatic data collection. We and our service providers may automatically log information about your interaction over time with the Service and our communications, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you.
Compliance and protection. We may use your personal information to:
Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Customers. The Customers to whom we provide the Service.
Affiliates. Our corporate parent and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email and SMS delivery, marketing, and website analytics).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Sojern or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Our Customers are the data controllers of end users’ personal information. As the data controllers, Customers are responsible for receiving and responding to requests to exercise any rights available to you under applicable data protection law. As such, if you wish to exercise a privacy right available to you, please contact the relevant Customer, and we will assist Customers in responding to such requests as required under relevant privacy law and in our contractual agreements.
Depending on your location and the nature of your interactions with our Customers, you may have the right to submit the following requests to Customers regarding your personal information:
Opting-out of marketing communications. You may directly opt-out of marketing-related emails sent via the Service by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. If you receive text messages via the Service, you may opt out of receiving further marketing text messages by replying STOP to the text message.
The Service may contain links to or integrations with websites, mobile applications, and other online services operated by third parties. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
For information regarding the EU-US Data Privacy Framework, please see the Sojern Privacy Policy.
The Service is not intended for use by children under 16. If we learn that we have received personal information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.
We may update this Privacy Policy from time to time in response to legal, technical or business developments, in which case we will revise the “last updated” date at the top of this Privacy Policy. When we update our Privacy Policy, we will inform you by posting a notice on the Website prior to such changes becoming effective, which will be consistent with the significance of the changes we make.
Email: sojernprivacy@sojern.com
Mail:
Sojern, Inc.
Attention: Privacy
545 Market Street, Floor 4
San Francisco, CA 94105