PRIVACY & COOKIE POLICY

Created on Jan 19, 2023

CORTIS operates an informational website and newsletter. We reserve the right to change this Privacy Policy at any time, so please review it on a regular basis. Any changes made to this Privacy Policy will be posted here and will notify you of any material changes. The date stamp at the top of the page represents the last day this Privacy Policy was updated.

This Privacy Policy applies only to the information we collect through the websites, electronic devices, and all products and services we provide, any other services that display this Privacy Policy, and all of the associated content, functionalities and advertising (collectively, the “Services”).

We do not collect any Personal Information from you when you use the Site or Services unless you provide it voluntarily. You are responsible for ensuring the accuracy of all Personal Information you submit to CORTIS. This Privacy Policy governs the Services regardless of how you access them.

This Privacy Policy describes the information we collect and how we collect it, what we do with the information we collect, how we share and disclose user information with third parties, CORTIS’s use of online analytics and tailored advertising, your California Privacy Rights, California Do-Not-Track disclosure requirements, how you can access and update your information, how we protect information, linked sites and advertisements, collection of certain information by third parties through our Services, use of the Services by users from outside the United States, use of the Services by children, how to contact us, no rights of third parties, changes to this Privacy Policy, and supplemental Privacy Notice for California Residents.

The information we collect and how we collect it.

How we collect and store information depends on the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.

INFORMATION YOU PROVIDE

We may collect information about you during your use of the Services, including but not limited to your name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, birth year, and information you provide or post on our Services or allow us to access, such as photos, video and/or audio, when you do certain things, such as:

enter registration information for one or more of our Services;
enter a sweepstakes or contest or register for a promotion;
participate in surveys or similar activities where users are asked to respond to a variety of questions;
request certain features (e.g., newsletters, updates, and other products);
connect with the Services or otherwise allow us to access certain information about you via a social networking site (“SNS”);
post user-generated content, including comments, to or on any of our Services;
navigate our websites; or
submit your information to us for any other reason.

We are not engaged in SNS tracking, however, we reserve the right to do so. Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via an SNS, that information can be viewed publicly and may be collected and used by third parties without our knowledge (or our consent) and may result in data collection by or unsolicited messages from other individuals or third parties.

We will use your email to deliver CORTIS's newsletter, as well as for other promotional (e.g., new product offerings, special offers by us or other third parties) purposes. Email messages we send you may contain code that enables our database to track your usage of the emails we send you, such usage includes whether the email was opened and what links (if any) were clicked. If you send an email to us, or fill out our forms, we will collect your email address and the full content of your email, including attached files, and other information you provide.

AUTOMATICALLY-COLLECTED INFORMATION

Device/usage information

We automatically receive and collect information such as your IP address, the URLs of websites you arrive at CORTIS from or leave CORTIS to go to, your type of browser and language, access times, the content of any undeleted cookies that your browser previously accepted from us, your operating system, your mobile provider, your mobile device, and your ISP. We may use such information to better understand how CORTIS visitors use the Site, to analyze trends, administer the website, prevent fraud, and gather broad demographic information.

Location information

We may collect different types of information about your location, including general information (e.g., IP address, ZIP code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. To do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details. We do not currently use geolocation for purposes of tracking your location when using CORTIS, but we reserve the right to do so.

Cookies and other electronic technologies

When you use the Services, we use persistent and session cookies and other similar tracking technologies to: (a) store your username and password; (b) monitor and analyze the usage of our sites and Services by collecting the information discussed in section 1 above; (c) customize the Services to your explicit and inferred preferences; and (d) tailor advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications. We along with our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we adopt additional technologies, we may also gather additional information through other methods.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services, and the advertisements you see may not be as relevant to you. We may also use Flash cookies. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. Please note that limiting third-party cookies through your browser controls will not necessarily opt you out of first- or third-party interest-based advertising, as some technologies (including those we or our partners may use) may not respond to these browser controls.To opt-out of interest-based advertising that is enabled by many industry platforms and providers (including much of the advertising described in this section), please see the choices we have described in Section 4, in particular the DAA’s opt-out page.

Information from third parties

We do not currently, but reserve the right to obtain additional information about you from third parties such as marketers, partners, researchers, social networks, data services companies (e.g., for data enhancement) and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

What we do with the information we collect.

Our primary purpose in collecting information, both Personal Information and any other information, is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your information to: provide the Services and customer support you request; troubleshoot problems and prevent potentially prohibited or illegal activities; customize, measure and improve our Site or Services, content and advertising; tell you about and administer our Site or Services, targeted marketing, service updates, contests, sweepstakes, rewards, and promotional offers based on your communication preferences; monitor and enforce our Terms of Service; communicate with Users about third-party products and/or services you may be interested in; verify your eligibility to use the Site or Services.

The Services are supported by advertising revenue. We may send you commercial emails on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you will have an opt-out that you can use to stop receiving such communications.

How we share and disclose user information with third parties.

CORTIS is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you. We may disclose Personal Information, Billing Information and Non-Personal Information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

We may also use and/or share your Personal Information, Billing Information and Non-Personal Information with, and you authorize us to use and/or share this information with:

Service providers under contract for business operations. We employ these companies and people to perform tasks on our behalf and may need to share your information with them to provide products and services to you.
Our affiliates and promotional partners, so they can offer you special products, services, discounts, tickets, and other items or services. Likewise, we may receive information from such affiliates and promotional partners to offer our Users special items or services.
We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by contacting us at privacy@cortis.com
In an ongoing effort to better understand our Users, we may analyze certain Non-Personal Information in anonymized and aggregate form in order to operate, maintain, manage, and improve CORTIS. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners and other third parties. We may also disclose aggregated user statistics in order to describe the Services and these products and services to current and prospective business partners and to other third parties for other lawful purposes.
We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference or by following the directions provided with the communication or advertisement.

CORTIS’s use of online analytics.

ONLINE ANALYTICS

We may use third-party web analytics services on our Services, such as those of Google Analytics and similar providers. These service providers use the sort of technology described in Section 1 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.

TAILORED ADVERTISING

While CORTIS does not currently engage in tailored advertising, we reserve the right to do so.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt-out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver interest-based advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link or TrustArc’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link that may be available through the Services.

Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.

You can also opt-out of ‘cross-app’ advertising — interest-based advertising that is associated with your use of our or other mobile applications. To do so, please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.We likewise may work with platform providers who serve advertising across devices. For instance, we may want to reach our web-based customers when they are on their mobile devices. This is done, generally, by correlating common attributes (such as IP addresses, other browser or device information or hashed email addresses) across devices, to infer a common identity across multiple channels. To opt-out of this type of advertising, you can do so by opting out of each separate device or browser, as we have described above.

No Spam or Spyware

We do not tolerate spam. Spamming is explicitly prohibited it by our Terms of Service. If you would like to report an incident of spamming or other unauthorized communications, please email privacy@cortis.com. We maintain the right to investigate such incidents and take suitable action.

Your California Privacy Rights

If you are a California resident, you may have certain rights. For more information, please see Section 16 below.

California Do-Not-Track disclosure requirements.

We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiative’s Consumer Opt-out link, Digital Advertising Alliance’s Consumer Opt-Out Link, TrustArc’s Advertising Choices page, and the Google opt-out link information in Section 4. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

How you can access and update your information.

To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at privacy@cortis.com

How we protect information.

We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process, and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that the information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

Linked sites and advertisements.

The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit sites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the site or Services in connection with such content, products, services, or functionalities, we may share any information you provide or that is collected during your use of those Services with those providers.

Collection of certain information by third parties through our Services.

For certain advertising that appears in the Services, an advertiser may request, and you may directly provide to that advertiser, information such as your name, home address, or email address. When you provide information in that way, the information you submit may be used by the advertiser in any way that it chooses, including to market to you, or to share with others. The information may be covered by the advertiser’s separate privacy policy, but in many cases that will not be the case because the advertiser may have no separate online presence. You should therefore only submit your information in these cases when you are comfortable doing so given the above conditions, and if you have any questions about the privacy practices of an advertiser, you should contact the advertiser itself.

Use of the Services by users from outside the United States.

The Services are hosted in the United States and locations outside the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States and other countries where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive or protective of certain rights as those in your country. Under United States law, your information may be subject to access requests from governments, courts, or law enforcement in the United States. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy and processed in those facilities.

Use of the Services by children.

The Services are not intended for persons under the age of 13. If we learn we have collected personal information from a child in a manner inconsistent with legal requirements, we will either delete the personal information or seek consent from parents or guardians. A parent or guardian may contact privacy@cortis.com to review personal information provided by the parent’s or guardian’s child, have such information deleted, and/or refuse to allow further collection or use of such information.

How to contact us.

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email at privacy@cortis.com

No rights of third parties.

This Privacy Policy does not create rights enforceable by third parties.

Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in our Privacy Policy above and applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees or job applicants.

SUMMARY OF INFORMATION WE COLLECT

California law, including the California Consumer Privacy Act of 2018 and related regulations (the “CCPA”), requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

CALIFORNIA NOTICE OF COLLECTION

(a) We or our service providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):

providing the Services (e.g., account servicing and maintenance, customer service, analytics, and communication about the Services);
our or our service provider’s operational purposes;
auditing consumer interactions on our site;
detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
bug detection and error reporting;
customizing content that we or our service providers display on the Services;
improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
other uses that advance our commercial or economic interests, such as communicating with you about relevant products and services available to you from third-party partners; or
other uses about which we notify you.

Examples of these types of uses are identified below and discussed more generally in our Privacy Policy above. We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent the identification of any particular user or device.

Strictly Necessary

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

DO NOT SELL MY INFO

California residents may opt out of the “sale” of their personal information. We do not currently sell your information to third parties to provide you with offers and promotions and opportunities that may be of interest to you, but we reserve the right to. Under the CCPA, sale is defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you. Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:

For online targeted advertising purposes: demographic and statistical information, user-generated content, device information and identifiers, browser and usage data, geolocation, and social media information.
For sharing with third parties to send you relevant offers, products, promotions and opportunities: contact and registration information, demographic and statistical information, employment and education data, user-generated content, device information and identifiers, and geolocation.

If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so using our website footer link. You can also submit a sale opt-out request by emailing us at privacy@cortis.com Please note that we do not knowingly sell the personal information of minors.

RIGHTS FOR CALIFORNIA CONSUMERS

If you are a California resident, you may have certain rights. California law may permit you to request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.

We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and physical address.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please email us at privacy@cortis.com

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

METRICS

California law may require us to compile metrics for the previous calendar year regarding consumer requests and responses. If required by applicable law, we will update this section after the CCPA has been in effect for a calendar year.

CALIFORNIA SHINE THE LIGHT

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email at privacy@cortis.com

ADDITIONAL CALIFORNIA RIGHTS

If you are a California resident under the age of 18 and are a registered User of our Services, you may be entitled to request that we remove from our Services content you posted to our Services that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Services may still remain on our servers and in our systems. To request the removal of content under this provision, please send an email to privacy@cortis.com and provide us with a description of the content and the location of the content on our Services, and any other information we may require to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Services by you.