Sojern Privacy Center
This privacy policy (the “Privacy Policy”) describes the types of personal information that Sojern, Inc. and its subsidiaries (“Sojern,” “we,” “our,” and/or “us”) collect, use, and disclose from individuals (“you” or “your”) who use our website, access our online properties, and interact with our advertising services (collectively, our “Services”). By using our Services, you agree to the collection, use, disclosure, and procedures described in this Privacy Policy. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.
As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual and includes any information that constitutes “personally identifiable information,” “personal data,” or “personal information” under applicable privacy or data protection laws or regulations.
You can visit the Privacy Center for additional information about the categories of personal information we collect and use and their different sources and purposes.
If you are a United States (“U.S.”) resident, please also review our U.S. State Privacy Notice for more information about the types of personal information we collect, use, and disclose, as well as how to exercise your rights under applicable U.S. state privacy laws.
We may collect a variety of personal information from or about you or your devices from various sources, as described below. Where applicable, we indicate whether and why you must provide us with your personal information, as well as the consequences of failing to do so. If you do not provide personal information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.
Registration. When you sign up for an account, we ask you for information which may include your email address, name, and date of birth.
Services. We collect the personal information you provide when you use our Services.
Contact Information. We may collect personal information that you provide voluntarily through our Services, for example when inquiring about or registering for our Services and events. This information includes your job title, company or organization, contact information such as your telephone number and email address, demographic information such as preferences and interests, and any information that you voluntarily choose to provide to us.
Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you sign up for our newsletter, we will collect your email address. When you communicate with us online, third party vendors receive and store these communications on our behalf. We may collect contact information, such as name, job title, business email, and phone number, from business representatives that are, or may become, Sojern customers or partners, in connection with our marketing and sales activities. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, your Location Information (described below), and your Device Information (described below). We may also receive information that you provide to us by way of surveys, and completed forms.
Careers. If you decide that you wish to apply for a job with us, you may submit your full name, contact information, including email address and phone number, employment-related information, your resume as well as academic records, work history and employment and personal references that you can choose to provide. You may also apply through a third-party service. If you do so, we will collect the personal information you make available to us through that service. We may collect sensitive personal information where we have an employment law obligation to do so, the information is relevant to place future employment benefits, or with your explicit consent. We do not use sensitive personal information to determine credit worthiness or eligibility for insurance, employment, housing, etc. We may need to conduct criminal background checks for some candidates for eligibility to work at Sojern. On a voluntary basis, we may also ask you to provide diversity information such as your race/ethnicity or veteran status for diversity monitoring purposes.
Payment Information. If you make a payment on our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
Location Information. We may collect and infer your general location information, including, for example, by collecting and using your internet protocol (IP) address.
Device Information. We receive information about the device and software you use to access our Services, including IP address, device type, device identifiers, internet service provider (ISP), data and time stamp, web browser type and version, extension version, crash logs or diagnostics, operating system version, phone carrier and manufacturer, application installations, and mobile advertising identifiers.
Usage Information. We automatically receive information about your interactions with our Services, like the pages or other content you view, referrer information (the website you visited before coming to our Services), and the dates and times of your visits.
Browsing Information. We automatically receive information about text, images, and media content on the web pages you visit, URLs and site metadata.
Information from Cookies and Other Tracking Technologies. We and our third-party partners collect information about your activities on our Services using, for example, cookies, pixel tags, SDKs, or other tracking and analytics technologies (“Cookies”). Our third-party partners, such as analytics, advertising, and security partners, may also use these technologies to collect information about your online activities over time and across different services.
Specifically, we may enable clients and partners to use pixels that automatically collect personal information from their online properties to share with us. Similar technologies to a pixel are used when you view an email from our clients or partners that has a Sojern tag, use a mobile application with a Sojern SDK installed, or see or interact with an online advertisement that was placed through our Services. This personal information may include:
For more information, please see our Cookie Policy, which includes information on how to control or opt out of these Cookies.
Information from publicly available sources and third-party sources. We may receive personal information regarding business prospects from online sources (e.g., where you have a professional profile posted online) and from third-party sources of business-to-business leads and contact information.
Customer relationship management. We may receive customer relationship management (CRM) data belonging to our clients and partners that reflects their online and/or offline interactions with individuals.
Contact information. We may provide direct email marketing services to our customers (e.g., sending emails on their behalf about experiences or travel opportunities you may enjoy). When we do so, we may receive your plaintext email address from our customer.
Audience data. We may receive audience data from our client and partners, such as information of preferences, interests and consumer segment in aggregated and pseudonymized form.
We use the personal information we collect:
To the extent required by applicable law, if you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland (together “Europe”), we only process your personal information when we have a valid legal basis, including as set forth below.
We may disclose your personal information with third parties in the following circumstances:
Partners and Affiliates. We may disclose any personal information we receive to our current or future affiliates and subsidiaries for any of the purposes described in this Privacy Policy.
Vendors and Service Providers. We may disclose any personal information we receive to vendors and service providers retained in connection with the provision of our Services.
AI Service Providers. We may disclose personal information we receive to vendors that provide artificial intelligence services that manage our customer communications and support, provide AI-assisted features within the Services, or that provide other backend support for our Services.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
Advertising Partners. We work with third-party advertising partners to collect and process your personal information in order to show you ads that we think may interest you.
Social Media. Our Services include third-party social media features that may collect your IP address and set cookies. These services are governed by their own privacy policies and are not within Sojern's control.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to:
Merger, Sale, or Other Asset Transfers. We may transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Consent. We may also disclose your information with your permission.
Marketing Communications. You can unsubscribe from our promotional emails by following the “unsubscribe” link found in these emails or emailing us at mktg@sojern.com. Even if you opt out of receiving promotional email messages from us, you will continue to receive administrative messages from us.
Partners and Subprocessors. You can visit our Partner & Subprocessor List for more information about our partners and data processors and your opt-out rights.
Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
Your Rights. You may exercise your rights by contacting us using the contact details as indicated in the “Contact Information” section below. You can also visit us here to access, export, or delete your personal information.
Opting-Out of Targeted Advertising. You may choose to opt-out of cookie-based targeted advertising from Sojern by following opt-out instructions in the Privacy Center. We comply with opt-out requests by placing an “opt-out” cookie on your computer or device, so, if you clear your cookies on that computer or device, we are unable to read the “opt-out” cookie. You may also change your browser settings so that cookies cannot be placed on your device and modify your mobile device settings for seeing advertisements. Additionally, you may choose to opt-out of receiving browser-based targeted advertisements from us by following opt-out instructions here:
If you wish to exercise your privacy rights related to the personal information provided by our clients or partners, we may help by directing your requests to them so they may appropriately respond.
Your European Privacy Rights. To the extent applicable, if you are located in Europe, you have the additional rights described below:
Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted by applicable law.
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any personal information to them.
To the extent required by applicable law, we take measures to delete your personal information or keep it in a form that does not permit identifying you when your personal information is no longer necessary for the purposes for which we process it unless we are required by law to keep your personal information for a longer period. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.
We make reasonable efforts to protect your data by using security measures designed to safeguard the data we maintain. However, because no electronic transmission or storage of data can be entirely secure, we can make no guarantees as to the security or privacy of your data.
We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at sojernprivacy@sojern.com. We will take steps to delete such personal information from our files as soon as possible.
Our Services are hosted in the U.S. If you choose to use the Services from Europe or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that your personal information is processed and stored in the U.S. We may also transfer your personal information from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.
If you are located in Europe, we will comply with applicable European data protection laws when transferring your personal information outside Europe. We may transfer your personal information to countries which have been found to provide adequate protection by the competent supervisory authorities as appropriate, use contractual protections for the transfer of personal information, transfer to recipients who have adopted Binding Corporate Rules, or rely on an appropriate legal derogation, to the extent necessary to comply with applicable European data protection laws.
In particular, Sojern complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Sojern has certified to the U.S. Department of Commerce that they adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF.
Sojern is responsible for the processing of personal information it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. Sojern complies with the DPF Principles for all onward transfers of personal information from the EU, UK, and Switzerland, including the onward transfer liability provisions.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Sojern commits to refer unresolved complaints concerning our handling of personal information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.
To the extent applicable, if you are located in Europe, you may contact us as specified below for more information about the safeguards we use to transfer personal information outside of Europe.
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted.
The entity that decides how and for what purposes we use your personal information (i.e., the data controller) for the Services is Sojern, Inc. If you are a candidate seeking employment at Sojern, the data controller is the relevant Sojern entity with whom you have engaged.
If you have any questions, comments, or concerns regarding the Privacy Policy or our processing activities, please feel free to email us at sojernprivacy@sojern.com.
You may also contact us via postal mail to the addresses below:
Sojern, Inc.
Attention: Privacy
545 Market Street, Floor 4
San Francisco, CA 94105
EU Representative:
Sojern International Ltd.
Attn: Privacy
34-37 Clarendon Street
Dublin 2
Ireland