Updated: August 15, 2020
If you have any questions about our use of your personal information, please contact us using the contact details provided at the bottom of this Policy at Contacting us.
Travel and travel planning often involves multiple Providers. Journera operates a technology platform that allows Providers to share information to help them better serve you, make your trip go more smoothly and to offer additional products and services relevant to you or your travel plans. For example, a hotel in partnership with an airline on the Journera platform, may offer you an early check-in upon learning that your flight is arriving in the morning. Journera provides services to facilitate this exchange of information between Providers who in turn are responsible for the way they use the shared information.
What information about you do we use?
We use information in connection with your travel and other services you purchased or shopped for from the Providers such as:
Identifiers including your name; address; telephone number; email address; Provider assigned customer ID numbers; and information about travel companions
Commercial information including goods and services purchased or shopped for; rates/fares/fees; reward or loyalty program information; travel itinerary and changes or cancellations thereto (such as dates and times of check-in/check-out and pick-up and drop-off); baggage information; public or private transportation; security agency information; and information and observations about your service preferences (such as room, seat, or car type, facilities, amenities requested, or any other aspects of the services used)
How do we collect your information?
Our primary sources of information are Providers, however we may supplement data from Providers with information we receive from third parties (e.g. fraud detection services and data validation services). We do not ordinarily collect any information from you directly, unless you choose to engage with us via post, email, social media or other means.
What do we use your information for?
We mainly use your information to provide our services to participating Providers, in our role as a processor or a service provider. In such cases, we use your information on behalf, and at the direction, of Providers. For instance, we use identifiers and commercial information to help us accurately match, or link, information about you that we receive from different Providers. For example, Journera uses your information to ensure a reservation you made with an airline relates to a separate hotel booking you made for the same trip. We also create a record of your travel planning and travel history to facilitate better matching capabilities. In addition, we use your information to help Providers keep informed of your plans and any changes to them as well as your preferences. One example would be sharing your flight booking and real-time arrival status with the hotel you have also booked so the hotel can properly anticipate your arrival.
In some limited circumstances, we also use your information for our own legitimate business interests such as to improve Journera’s products and services and to create new ones, or to protect and maintain our products and services. We also use your information to create and share with Providers aggregated, de-identified or anonymized statistics and reports about things such as general travel habits, preferences, business trends or the use of our services.
With whom do we share your information?
In connection with the uses set out in this Policy, we may share your information as follows:
Providers: In our role as a processor or service provider acting on behalf and at the direction of Providers, we may share with Providers the information that we process about you as described above. Those Providers who process your information in their own right are responsible for their own use of your information and their use will be governed by their own privacy policies. We are not responsible for the use or disclosure of your information by a Provider (or any third party). For information about the practices of Providers or third parties, please review their privacy policies.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, information may be part of the transferred assets.
Related Companies: We may share information with our subsidiaries and affiliates for purposes consistent with this Policy.
Legal Requirements: Journera may disclose information 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 and defend the rights or property of Journera, our agents, Providers and others, including to enforce our agreements and policies; (iv) act in urgent circumstances to protect the personal safety of any person; (v) to protect against legal liability; or (vi) to prevent or stop activity we consider to be illegal or unethical.
Do we sell your information?
Journera does not sell your personal information.
How do we protect your information?
Journera takes your privacy seriously and employs technical and organizational security measures to protect your information from unauthorized access, loss and misuse. The contracts we have in place with Providers require us to use these security measures and they are included in our internal policies and procedures.
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, for more information about the information collection and usage practices of Providers, please see their respective privacy policies.
Where will your information be held?
Your information may be stored and accessed 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 information is provided to us, we may transfer it to the United States. Providers may access your information from any location in which they operate. Where required, we seek to put data transfer mechanisms in place (such as the Standard Contractual Clauses or the Privacy Shield) to ensure compliance with data transfer laws.
How can you exercise your rights and choices over your information?
It is important to Journera that you are able to exercise control over your information. Where we have noted that we act as a service provider or a processor on behalf of the Provider, it is the Provider's responsibility to ensure that you are able to exercise your rights over your information. Journera works closely with Providers to help ensure that is the case. Thus, in such cases, we invite you to directly contact Providers to exercise your privacy rights.
In the limited circumstances where we use your information for our own legitimate business interests, depending on where you are resident and the particular circumstances that apply to our use of your information, you may have the right to contact us to exercise the following data protection rights:
to access, correct, update or request deletion of your information;
to object to or restrict processing of your information;
to request portability of your information;
to opt-out of marketing communications (if we were to ever send you any);
to withdraw your consent at any time (in the event that we were to rely on the legal ground of consent); and
to lodge a complaint with your supervisory authority or data protection regulator about our collection and use of your information.
To exercise these rights, please use the contact details provided under the "Contacting us" heading below. Please be as specific as possible in relation to the personal information about which you inquire. Once we receive your request, we will review it, determine whether we can verify your identity by a method appropriate to the type of request you are making, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
How long do we retain your information?
Where we act on behalf of the Providers, we retain your information in accordance with our contract with the relevant Provider. Otherwise, we retain your information where we have an ongoing legitimate business need to do so and for a period of time consistent with the original purpose as describe in this Policy. After expiration of the applicable retention periods, we will either delete or anonymize your personal information or, if this is not possible, then we will securely store your personal information.
International Transfers and Privacy Shield
Where required by applicable laws, Journera takes steps to implement safeguards to protect the information transferred outside of its country of origin, such as executing the standard contractual clauses or relying on the EU-U.S. and Swiss-U.S. Privacy Shield Framework. If you are an individual of the EEA, the United Kingdom or Switzerland, 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 information transferred from the European Union and the United Kingdom and/or Switzerland to the United States, as applicable. 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.
Journera is committed to timely resolving complaints about your privacy and our collection or use of your 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. Contact details for national supervisory authorities in the EEA are available here.
Changes to this Policy
We may change this Policy from time to time. The most recent version of the Policy is reflected by the version date located at the top of this Policy. If we make material changes to this Policy, we will prominently post a notice of such changes prior to implementing the changes. We encourage you to review this Policy frequently to be informed of how Journera is protecting your information.
If you have any questions about this Policy or how we use information about you, you can contact us at email@example.com, or via mail at Journera, Inc., Attn. Privacy Officer, 350 N. Orleans St. #9000N, Chicago, IL 60654, USA. 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 firstname.lastname@example.org.