Privacy Policy

Last updated on August 28, 2019.

This Privacy Policy discloses the policies of Cortlandt Street Holdings, Inc. (“Cortlandt,” “we,” or “us”). Cortlandt’s Privacy Policy describes the type of personal information collected by Cortlandt, how Cortlandt uses that information and, most importantly, how Cortlandt protects that information. By accessing or using Cortlandt’s website (, along with our related websites, networks, applications, mobile applications, and other services provided by us (collectively, “Services”), you agree to Cortlandt’s End User License Agreement (“EULA”) and this Privacy Policy, and that Cortlandt may transfer and store your information in the United States.

Please be aware that the privacy and legal requirements, including the rights of authorities to access your personal information, in countries other than the United States may not be equivalent to those in the United States. If you use Services outside of the United States, you consent to the transfer of your Personal Data to the United States by your use of any Service. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES. This Privacy Policy covers:

  1. The Information Cortlandt Collects;
  2. How Cortlandt Uses the Information It Collects;
  3. Information Sharing and Disclosure;
  4. Information Access and Retention;
  5. Date Processing;
  6. Contact Information; and
  7. Changes to this Policy.

1. The Information Cortlandt Collects.

How Cortlandt collects and stores information depends on the websites you visit, the activities in which you participate, and the Services you use. Several categories of information are collected from you, as described below.

1.1 Information You Provide

Cortlandt may collect information about you during your use of the Services, including other information you provide or post on Services or allow Cortlandt to access when you do certain things, such as:

  • Provide registration information and/or create an account;
  • Access Cortlandt’s website (
  • Download or use one of Cortlandt’s mobile applications;
  • Contact customer support; or
  • Upload user-generated content.
  • Register for premium Services

The information Cortlandt collects about you when you use Services, or when you engage in any of the above actions (collectively referred to as “Personal Data”) may include:

  • Contact Information – your name, picture, email address, postal address, phone number, and other similar identifying information;
  • Account Information – your username, password and other log-in details used to access Services; or
  • Payment Information – your credit card number and billing information used to register for premium Services; or
  • Location Information – the current location of your mobile device.

1.2 Registered User Profile

Registered users have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include information that pertains to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, income records, health, sexual orientation or alleged commission of any offense (”Sensitive Information”) on your profile and to make that Sensitive Information public. Please do not post or add personal information to your profile that you would not want to be publicly available.

1.3 Posting and Uploading

Cortlandt may collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data), respond to a survey, or submit a resume. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about them, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.4 Service Use

Cortlandt may log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles, or otherwise interact with the Services. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.5 Cookies and Other Electronic Technologies

Cookies and other ad technology such as beacons, pixels, and tags help us serve relevant ads to you more effectively. They also help us provide aggregated auditing, research, and reporting for advertisers, understand and improve our service, and know when content has been shown to you. Note: Because your web browser may request advertisements and beacons directly from third party ad network servers, these networks can view, edit, or set third party cookies, just as if you had requested a web page from their site. Ads served by Cortlandt may also set third party cookies.

If you are logged into our Services that references this Cookie Policy or browsing a third party partner site of Cortlandt and one of our cookies on your device identifies you, your usage (such as your browsing behavior) and log data (such as your IP address), will be associated by us with your account. We also use aggregate data from third parties and data from your profile and activity.

If you are a registered user but logged out of your account on a browser, Cortlandt may still continue to log your interaction with our services on that browser for up to 30 days in order to generate usage analytics for our services, which analytics we may share in aggregate form with our advertising customers.

Unless you clear these cookies from your browser, we may use this information to:

  • Provide more relevant, interest-based advertising
  • Provide aggregate reports of ads activity to advertisers and websites hosting the ads
  • Help website and app owners understand how visitors engage with their sites or apps
  • Detect and defend against fraud and other risks to protect users and partners
  • Improve our products

Cortlandt uses cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising. Please note that some Services may not work properly without cookies.

1.6 Location

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.7 Messages

We may collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a contact request, we may track whether you have acted on it and will send you reminders. We may also use automatic scanning technology on messages.

1.8 Sites and Services of Others

We may receive information about your visits and interaction with services provided by others when you log-in with Cortlandt or visit others’ services that include our plugins (such as “Share on Cortlandt” or “Apply with Cortlandt”), ads, cookies or similar technologies.

1.9 New Services or Features

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2. How Cortlandt Uses the Information It Collects.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others.

2.1 Contacts

Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you will “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your settings, when you connect with other registered users, you will be able to search each others’ connections in order to exchange professional opportunities.

It is your choice whether to invite someone to our Services, send a connection request, or allow another registered user to become your connection. When you invite someone to connect with you, your invitation will include your name, photo, network and contact information. We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

2.2 New Services or Features

Our Services are dynamic, and we often introduce new features, which may use your information in new ways. If we materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2.3 Premium Services

We may sell premium Services that provide our customers and subscribers customized-search functionality and tools (including messaging and activity alerts) as part of our talent, marketing and sales solutions. Customers can export limited information from your profile, such as name, headline, current company, current title, and general location (e.g., Houston), in order to manage sales leads or talent, unless you opt-out. We do not provide contact information to customers as part of these premium Services without your consent. A premium Services customer can store information he/she has about you in our premium Services, such as a resume or contact information or sales history. The data provided about you by these customers is subject to the policies of those customers.

2.4 Communication

We will contact you through email, mobile phone, notices posted on our websites or apps, messages, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

2.5 Advertising

Cortlandt targets (and measure the performance of) ads to registered users, visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Registered user provided information (e.g., profile, contact information, title and industry);
  • Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1;
  • Information from advertising partners and publishers; and
  • Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender).

Cortlandt will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the Cortlandt Services, that action may be mentioned with related ads.

Cortlandt adheres to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads.

Cortlandt does not share your personal data with any third-party advertisers or ad networks for their advertising except for: (i) hashed or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., lead generation form) or (iii) data already visible to any users of the Services (e.g. profile). However, if you view or click on an ad on or off our site or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

2.6 Marketing, Development, and Research

Cortlandt may use data and content about registered users for invitations and communications promoting membership and network growth, engagement and our Services.

Additionally, Cortlandt uses data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

Cortlandt also uses the personal data available to us to research social, economic and workplace trends such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.7 Customer Support and Security

Cortlandt uses the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

Cortlandt uses your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our EULA or this Privacy Policy and/or attempts to harm our registered users or visitors.

2.8 Other Uses

Cortlandt uses your data to produce and share aggregated insights that do not identify you. For example we may use your data to generate statistics about our registered users, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or demographic workforce insights.

3. Information sharing and disclosure.

3.1 Visible Information

Subject to your settings, your profile may be fully visible to all registered users and customers of our Services.

3.2 Other Services

Cortlandt may share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others.

3.3 Service Providers

Cortlandt uses others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.4 Legal Compliance

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Cortlandt, our registered users, personnel, or others. We attempt to notify registered users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.5 Change in Control

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Information Access and Retention.

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. In some cases we choose to retain certain information in a depersonalized or aggregated form.

4.1 Account Closure

If you choose to close your account, your personal data will generally stop being visible to others on our Services within 72 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Registered users copied out of our Services.

4.2 How Cortlandt Protects Information.

We implement security safeguards designed to protect your data. However, we cannot warrant the security of any information that you send us. Although Cortlandt takes appropriate measures to safeguard your information, there is no guarantee that your information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5. Data Processing

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)) and “legitimate interests”.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us using the information below.

6. Contact Information

The Service is offered by Cortlandt Street Holdings, Inc., located at 6134 Valley Forge, Houston, Texas, 77057. You may contact us by sending correspondence to that address or by emailing us at

7. Changes to this Policy.

Cortlandt can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.