Journera, Inc.
Privacy Policy
Last Updated: May 15, 2018

Protecting your privacy is very important to Journera, Inc. (“Journera”, “we” and “us”). A key part of protecting your privacy is keeping you informed about our business and how we handle the information we receive. We provide this Privacy Policy (“Privacy Policy” and “this Policy”) to explain how we collect, use and share information that we receive about you from providers of travel and travel-related products and services with whom you have engaged, and from other third parties.

We encourage you to use the links below to find out more about Journera, the information we may collect about you, how we use it, and to whom we disclose your personal information.

About us

Travel and travel planning often involve multiple services, such as airlines, hotels, cruise, transfers, rental cars, travel agents, tours, trip insurance, destination entertainment, restaurants and even social media. Journera operates a technology platform that can link the planning and arrangements you engage in with each of them, allowing them to share information to help them better serve you and to offer additional products and services directly relevant to you and your travel plans. A simple example is a hotel you booked that learns through Journera that your flight home leaves at 8:00pm, might offer you late checkout. Journera offers this linking service directly to participating companies that offer travel or travel-related products and services (“Providers”), and they are responsible for the way in which they use the shared information.

If you have any questions about this Policy or how we use information about you, you can contact us at privacy@journera.com, or at Journera, Inc., Attn. Privacy Officer, 350 N. Orleans St. #9000N, Chicago, IL 60654. Our data protection officer is also available to help you understand the measures we take to ensure we process your personal information appropriately. You may contact our data protection officer at privacy@journera.com.

What information about you do we collect?

Unless you choose to contact us or engage with us on social media, we do not collect any information from you directly. We receive information about you from Providers and from other sources described herein.

Once you begin to engage with a Provider, it may provide us with two types of personal information about you: Verification Information and Travel Information. “Verification Information” is your contact and identification information. Verification Information is handled by us with special precautions, used by us only for a very specific purpose, and is not shared with others. Verification Information includes data such as: name, address, telephone number, email address, date and place of birth, gender, nationality, public or private transportation security agency information, loyalty program numbers, Provider assigned customer ID numbers, truncated credit card number, association identification numbers (such as AAA), and driver’s license, passport, visa or other government-issued identification information.

Travel Information” is information related to your trip or trip planning and includes information such as: travel itinerary and changes or cancellations thereto, dates and times of check-in/check-out and pick-up and drop-off, baggage information, whether you are travelling with companions (including children), goods and services purchased, special requests or accommodations made, information and observations about your service preferences (including but not limited to room, seat, or car type, facilities, holiday preferences, amenities requested, or any other aspects of the services used), reward or loyalty program information, and rates/fares/fees.

We may also obtain information that relates to your travel or helps us more accurately match or link your various transactions from other third-party sources, including customer information bureaus, data validation services, and information publicly available on social media. We will handle Verification Information and Travel Information received from these third-party sources in the same way that we handle information received from Providers.

What do we do with your information, and how do we protect it?

Verification Information is used to help us accurately match, or link, information about you that we receive from different Providers. For example, Journera uses your Verification Information to ensure a reservation you made with an airline relates to a separate hotel booking you made for the same trip. We subject this information to special data protection processes.

When we obtain Verification Information about you from a Provider, and before we store it, it is processed using complex mathematical technologies to turn the original information into an unreadable string of characters that look nothing like the original information. Because the same piece of original information, say a telephone number, will generate the same string of characters each time, we can compare the strings of characters created from the same pieces of information received from different Providers to help us make accurate links without Journera knowing or storing your telephone number or any of the other pieces of Verification Information. Verification Information is not shared by Journera, even between Providers on your trip. For example, if you provided an email address to an airline, but not to your hotel, Journera will not provide it, or any other element of Verification Information to the hotel.

Travel Information is the information about you that Journera may cause to be shared between Providers with whom you’ve already engaged. One example would be sharing your flight booking and real-time arrival status with the hotel you have also booked so they can properly anticipate your arrival. To protect your privacy but still allow a Provider to understand the information, your Travel Information is transmitted using industry standard encryption and linked to a uniquely coded key that represents your identity. Only an authorized Provider with secure access to Journera can receive the encrypted Travel Information. To use the Travel Information, the Provider must have the ability to link the key to your identity with existing records in their system. This means that only Providers that you have engaged with can access your Travel Information.

In addition, we may compile your historical Travel Information to be able to inform Providers with which you choose to do business about your individual preferences when you travel and travel history, which may include travel with other Providers.

We may also use Travel Information, in aggregated and anonymized formats that do not allow, directly or indirectly, you to be identified or information to be linked to you, for business research, statistical analyses, and to develop certain data products, which may be used by us or third parties for business and marketing purposes.

And finally, Journera may use internally all information it receives to improve the performance of our platform.

In addition to the processes described above, Journera employs additional administrative, physical and electronic measures designed to protect your Verification Information and Travel Information from unauthorized access. These measures include having appropriate contractual terms in place with Providers and other third parties that are in compliance with applicable data protection laws; employing transport layer security (TLS), or similar technology, in the transmission of information, and information storage security technologies to block unauthorized access from outside our network. We also make it easy for you to control the way in which we use your Verification Information and Travel Information (See How can you control your information, below).

Please be aware, however, that no method of transmitting information over the Internet or storing information is perfectly secure. Accordingly, we cannot guarantee the absolute security of any information. Please also be mindful that although we consider the data security processes of Providers who may have access to information about you, we are not responsible for their security measures. As noted below, for more information about the information collection and usage practices of Providers, please see their respective privacy policies.

With whom do we share your information?

Journera will only share information about you with third parties in ways that are described in this Privacy Policy.

As discussed above, Journera will not share your Verification Information with any third parties including the Providers you’ve chosen to serve you. Verification Information is used only to help us accurately match, or link, information about you across Providers.

All Travel Information we receive may be shared with Providers with whom you have done business. Accordingly, those Providers who process your information in their own right are responsible for their own use of the Travel Information and their use will be governed by their own privacy policies. Providers have agreed to use such information for the limited purposes of: (a) communicating with you; (b) personalizing your shopping and booking process; (c) improving delivery of in-trip products and services to you; (d) facilitating delivery to you of post trip-related products and services like reviews and expense reporting; (e) improving the relevance and personalization of subsequent offers made to you; and (f) facilitating data exchange agreements between Providers.

We are not responsible for the use or disclosure of your information by a Provider or any third party receiving your information from a source other than Journera. For information about the practices of Providers or third parties, please review their privacy policies. If you wish to unsubscribe to marketing by a Provider or any third party or have questions about their use or disclosure of information about you, you will need to contact them directly.

We may disclose information to companies affiliated with Journera, and to unaffiliated third parties selected by us to help support our technical operations, including improving, developing or hosting our website, software or the products and services we provide. These third parties may have access to our systems and your information only for purposes of performing tasks on our behalf, we contractually require them to protect your information consistent with this Privacy Policy, and we remain liable for their compliance with this Privacy Policy.

In addition to Travel Information made available to Providers, we may make data generated from information we receive available to our business customers, business partners, and other third parties, but only in aggregated, anonymized formats that do not allow, directly or indirectly, the identification of you.

Specific Exceptions. Journera reserves the following rights with respect to information it receives about you. However, the measures Journera takes to protect your personal information, in particular your Verification Information, may limit the effect of these exceptions on you and your information.

Merger or Sale of the Business: We may transfer or disclose all or some of the information discussed in this Policy in connection with a corporate merger, acquisition, lease or sale of assets, bankruptcy or other change in corporate status.

Government or Legal Demand: We reserve the right to disclose information we receive to government, regulatory, or law enforcement officials or to private parties as we, in our sole discretion, believe necessary to: (i) satisfy or comply with any applicable law, regulation, legal process, or national security or law enforcement requirements having the force of law; (ii) respond to lawful requests, including subpoenas, warrants or court orders; (iii) protect our property, rights, and safety and the rights, property and safety of third parties or of the public in general; and (iv) prevent or stop activity we consider to be illegal or unethical.

Where will your information be held?

Your Verification Information and Travel Information may be stored outside of your state or country, where the privacy laws may not be as protective as those where you live. If you’re located outside the United States and your Verification Information and Travel Information is provided to us, we may transfer it to the United States. Providers in whichever location they may be may access your Travel Information. If you are an individual of the EU or Switzerland, please review the Cross-Border Transfers section below.

Cross-Border Transfers

Journera complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Journera has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/list. The Federal Trade Commission has jurisdiction over Journera’s compliance with Privacy Shield.

What is our legal basis on which to process your information?

Journera’s contracts with Providers require them to affirm that they have all necessary rights or permissions to share your personal information with us for the purposes described above. We consider our processing to be fair and in the interest of you, us and Providers as it enables Providers to provide you with enhanced and improved products and services. For example, our processing:

  • Allows Journera to accurately link your shopping activity, bookings and reservations among different Providers with which you have engaged;
  • Facilitates communication between the Providers you’ve selected to help your trip and trip planning go more smoothly;
  • Facilitates the delivery of in-trip products and services to you, enhancing and streamlining your travel experience;
  • Facilitates and improves communication between you and Providers;
  • Facilitates the delivery of post-trip related products and services, such as reviews and expense reporting, improving efficiencies for the traveller and providing Providers with targeted and relevant traveller feedback; and
  • Enables Providers to give you more relevant products, services, and offerings from Providers.

As stated above, our interest is in providing a platform for the exchange of travel information among Providers serving an individual on a particular trip, or for related improvements in travel and travel-related services. We balance these interests with your interests in the following ways:

  • For your protection, your Verification Information is processed in a manner making the original information unreadable, but so that we can still use it to match and link your interactions with various Providers;
  • Your Travel Information is collected, stored and transmitted in a manner that protects your identity in that only Providers with whom you’ve already chosen to engage will have access to such information and know that it is associated with you. This function is intended to help Providers serve you better;
  • To the extent that we use your information for other purposes, it is to develop business analytics, including personalization strategies, and other reports to improve travel marketing and delivery of travel and travel-related services or information to consumers; and
  • We may also use your Verification Information and Travel information to improve our own system and services and other typical and legitimate business reasons.

How can you control your information?

It is important to Journera that you are in control of your personal information and Journera works closely with Providers to help ensure that is the case. To exercise control with respect to your personal information or to request that your Provider not share your personal information with Journera, it is best if you contact directly your Provider that may be sharing your data with us. We will make any changes to the information we hold if requested to do so by a Provider as a result of you exercising your rights.

If you prefer, you may contact us directly at privacy@journera.com and we will assist you with the exercise of your rights, including limiting our use and disclosure of your personal information, and coordinate with the relevant Providers that we are able to identify as having shared your information with us. You may wish to contact us directly in particular if you no longer want Journera to:

  • Process your personal information from any or all Providers;
  • Onward transfer your personal information to any or all Providers;
  • Utilize your personal information for purposes of profiling or automated decision making; or
  • If you would like Journera to remove your personal information from the Journera platform.

If you or the relevant Provider are in Europe or Switzerland, you may have the following rights. They do not apply in all circumstances. If you wish to exercise any of them, please contact the relevant Provider. You may also contact Journera at privacy@journera.com and we will promptly assist you with the exercise of your rights.

  • The right to request access to your personal information and to obtain information about how we process it;
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
  • The right to object to processing of your personal information;
  • The right to restrict processing of your personal information;
  • The right to have your personal information erased (the “right to be forgotten”);
  • The right to move, copy or transfer your personal information (“data portability”); or
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

Please Note: Given the processing we use with respect to your Verification Information, we are unable to provide you with a copy of the information we hold, but we can tell you, for instance, that we have received your telephone number and from whom we received it.

If you have any concerns about the way in which we use your personal information, please contact Journera at privacy@journera.com. Journera is committed to timely resolving complaints about your privacy and our collection or use of your personal information. If we are unable to resolve your concern, Journera has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. 

As a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism or to the extent that Journera’s data processing is subject to European laws, you may raise a complaint with your national supervisory authority.

How long do we retain your information?

We may retain your Verification Information and Travel Information while you are an active customer of any Providers and, in order to facilitate providing services to even the infrequent traveller, for seven (7) years thereafter. In certain circumstances, we may be required to retain your information for longer, where law or record keeping requirements requires such retention.

Providers’ use of cookies

Some Providers may use cookies, pixel tags, Adobe Flash technology, device identification, analytical tools and other similar technologies launched from a Provider or other party’s website you interact with to transmit information about you to Journera. Please see your Provider’s policy for further information with respect to a Provider’s use of such technologies and how you might disable same. You may also utilize your browser controls to control such technologies execution on your device.

Changes to this Policy

Any Verification Information or Travel Information that we collect is subject to the version of this Privacy Policy in effect at the time that information is collected.