Privacy Policy

Last Revised: September 21, 2026

Effective Date: September 21, 2026

We, Cortland International Inc. (“Cortland,” “we,” or “us”), are committed to protecting the privacy and security of personal information and to transparency about how we use personal information (also known as personal data). This Privacy Policy sets forth our policies and practices for collecting and using personal information in connection with our website and any other services that link to this Privacy Policy (our “Services”). This Privacy Policy does not address our use of personal information outside the context of the Services.

For purposes of this Privacy Policy, we regard personal information as any information that relates to an identified or reasonably identifiable person.

Within the context of the Services, this Privacy Policy explains how we use and disclose personal information. It also discusses how you can control certain uses and disclosures of your personal information. We will update this Privacy Policy from time to time, or as our privacy practices change, to ensure it accurately describes how we use personal information. When we do so, we will update the dates above. We recommend that you review this Privacy Policy occasionally for the latest information. If we change our practices in a material way, we will provide appropriate notice to you, usually through an email or through a banner or pop-up within our Services.

If you have any questions regarding this Privacy Policy or our use of your information, please contact our privacy office (which also serves as our Grievance Officer for purposes of privacy law compliance) using one of these methods:

Postal mail at Cortland International, Privacy Manager, 10633 West Airport Blvd Ste 300, Stafford TX 77477
Our website: https://www.cortlandinternational.com

When you contact us, please let us know in which country and state you reside.

1. How we use and disclose personal information

We limit the collection and processing of personal information to that which we need for our business purposes, as explained in the following table and the text that follows it:

Categories of individuals	Categories of personal information	Purposes	Methods of collection	Categories of third-party recipients (see below)
All website users	General device, usage, and activity information	To provide the website Service analysis, security, and administration	Directly from user Indirectly by observing users’ activities or behavior	None
Website users who have not opted out of our use of analytics technologies	Detailed device, usage, and activity information Approximate location information Pseudonymous analytics identifier	Service analysis, security, and administration	Our analytics provider collects this information through analytics technology operating on the user’s device	Analytics providers, including Google Analytics
Individuals who send us inquiries or other correspondence	Sender name and email address Contents of inquiries or other correspondence	To respond to inquiries or other correspondence	Directly from individual	None

In the table above, “General device, usage, and activity information” means information ordinarily logged when a user accesses the website, such as IP address, browser or device characteristics, requested pages, and timestamps. “Detailed device, usage, and activity information” means additional information collected through analytics technologies about how a user interacts with the website, such as navigation paths, referral sources, session and engagement information, and specific interactions with website content

Please be aware that we use third-party technologies for analytics purposes. As a result, our analytics provider(s) will receive personal information about you, as described in the table above.

At present, we do not collect or process personal information considered to be “Sensitive Information,” “Sensitive Personal Information,” or “special category data” under various privacy laws in connection with our Services.

2. Disclosure

In addition to the disclosures to third parties described in the table above, we may also disclose your personal information to:

Processors/service providers. We disclose your personal information to third parties that provide services to us. We engage these third parties with contracts that require them to use your personal information only for the purpose of delivering the services for which we have engaged them and as required by law. These kinds of third parties typically provide website hosting, business, professional, administrative, or technical support functions for us.
Legal compliance recipients. We disclose personal information to the courts, governments, law enforcement agencies, litigants, and similar recipients when required by law.
To advance or defend against legal claims. We may also disclose personal information to the extent needed to advance or defend legal claims.
Successors. We may disclose personal information associated with a part of our business to a buyer, potential buyer, or other successor to our business.

We also may disclose personal information to third parties with your consent or at your direction.

Because no consensus has emerged on how to process a web browser’s “do not track” signal, we do not currently take any action in response to the signal. When we detect the Global Privacy Control signal (or the use of another universal opt-out mechanism), we treat that as a request to opt out of the selling of your personal information or its use for behavioral advertising.

3. Security, quality, and retention

We use reasonable administrative, technical, and physical safeguards to protect personal information in our possession from misuse, interference, loss, unauthorized access, modification, or disclosure. While we make every reasonable effort to help ensure the integrity and security of our network and systems, you should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be completely secure, accurate, complete, or current.

We also take reasonable steps so that the personal information we collect is sufficiently accurate, up-to-date, and complete for the purposes for which we process or disclose it.

We retain personal information for as long as is necessary for the purposes for which we use it, or for so long as required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when determining how long to retain personal information:

retention periods established under applicable law;
industry best practices;
whether the purpose of processing is reasonably likely to justify further processing;
risks to individual privacy in continued processing;
applicable data protection impact assessment;
information systems design considerations/limitations; and
the costs associated with continued processing, retention, and deletion.

4. International users

Please be aware that your personal information will be stored and processed in the United States, where our servers are located.

5. Children’s privacy

We are very concerned about the safety of children using the Internet. Our Products and Services are not directed at children and we do not knowingly collect any personal information from those under the age of 16.

If we discover (or are informed) that we have collected personal information from a visitor under the age of 16, we will promptly delete such information.

6. Your privacy rights (for individuals in the State of California)

We provide the following privacy information for residents of the State of California.

A. Collection of Personal Information

The following table lists the categories of personal information we have collected in connection with the Services in the last 12 months in the fashion required by Cal. Civ. Code § 1798.130(a)(5)(B)(i).

Category under the California Consumer Privacy Act	Specific Legal Description	Collected
A. Identifiers	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Customer records (as defined in Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information.	Yes
C. Protected classifications	Characteristics of protected classifications under California or federal law, such as race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), and age over 40.	No
D. Commercial information	Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information	An individual’s physiological, biological, or behavioral characteristics, including DNA information that is used or is intended to be used to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No
F. Usage data	Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.	Yes
G. Geolocation data	Data intended to locate a customer within a geographic area.	Yes
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment information	Your job role, professional and educational qualifications, employment and education history, compensation information and similar data.	No
J. Education information	Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act, including education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences	Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

B. Collection of Sensitive Personal Information

As required by Cal. Civ. Code § 1798.100(a)(2), we disclose that we do not and have not within the past year collected sensitive personal information.

C. Disclosure of Personal Information for a Business Purpose

As required by Cal. Civ. Code § 1798.130(a)(5)(C), the following table lists the categories of personal information that we have “sold” or “shared for cross-context behavioral advertising” with third parties or disclosed for our business purposes in the past twelve months.

Category under the California Consumer Privacy Act	Sold or Shared in the Last 12 Months	Disclosed for a Business Purpose in the Last 12 Months
A. Identifiers	Yes	Yes
B. Customer records (as defined in Cal. Civ. Code § 1798.80(e))	No	Yes
C. Protected classifications	Not collected	No
D. Commercial information	Not collected	No
E. Biometric information	Not collected	No
F. Usage data	Yes	Yes
G. Geolocation data	Yes	Yes
H. Sensory data	Not collected	No
I. Professional or employment information	Not collected	No
J. Education information	Not collected	No
K. Inferences	Not collected	No

To understand more about the purposes for which we collect personal information, see section 1, above.

D. Your Rights

If you are a California resident, California law gives you a number of rights relating to your personal information, including:

the “right to know,” meaning the right to request any or all of the following:
- the specific pieces of personal information we collected about you;
- the categories of personal information we collected;
- the categories of sources used to collect the personal information;
- the business or commercial purposes for collecting your personal information; and
- the categories of third parties with whom we have shared your personal information;
the right to request deletion of your personal information that we collected;
the right to have someone you authorize make a request on your behalf;
the right to opt out of “sale” (as that term is defined in the law) or the sharing of personal information for cross-context behavioral advertising purposes;
the right to make a request for the correction of errors or inaccuracies in your personal information;
the right to restrict the processing of sensitive personal information (please note, however, that we do not collect or process sensitive personal information); and
the right not to be discriminated against for exercising any of these rights.

E. Appeal process

You may appeal our decision regarding your request to exercise your legal rights with respect to your personal information. To submit an appeal, you may contact us using the contact information above. You must include sufficient information to allow us to reasonably verify your identity, reference the date and time of your previous request to exercise your legal rights, and explain why you believe our decision was insufficient or improper. We will respond to your appeal in accordance with the timelines set forth in applicable law.

F. Opting out of the Sale or Sharing of Personal Information

You can opt-out of the sale or sharing of your personal information through our consent tool or using a universal opt-out mechanism such as the Global Privacy Control.

G. Exercising Your Other Rights

You may exercise these rights by contacting us using the information at the top of this Privacy Policy.

Please note that, although you have the right to request that we restrict our processing of sensitive personal information to only that which is necessary to deliver our products and services to you, we do not collect sensitive personal information. If you have any questions or requests relating to this topic, please contact us using the contact information provided above.

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your right to the deletion of your information. You may designate an authorized agent to make a request to know or request to delete on your behalf. An agent may be an individual, or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly as permitted by law. We may refuse a request if the agent does not provide adequate proof of their authorization.

We may not discriminate against you for exercising any of the above rights available to you under California law. This means that we may not deny you services or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to such a request made under California law. However, as permitted by law, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

H. Shine the Light

California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, entitles California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not presently make any such disclosures. Any other inquiries regarding personal information sharing with third parties may be directed to us at the contact information set forth above.

7. Your privacy rights (for individuals in the United States)

If you live in the United States of America, depending on the law in the State where you live, you may have certain rights regarding your personal information under the law. To exercise your rights, please submit a request by contacting us through any of the means outlined above.

Your rights may include the following:

the right to opt-out of the use of personal information for targeted advertising, personal information sales, or profiling resulting in significant consequences (note, however, that we do not engage in such profiling);
the right to confirm whether we process your personal information and to access a copy (from which we may, for security purposes, exclude certain personal information), including a copy that is in a portable data format;
the right to the correction of inaccurate personal information;
the right to the deletion of your personal information; and
the right to appeal the action we take in response to any request to exercise these rights.

You can exercise your right to opt-out of the use of personal information for targeted advertising and personal information sales by using our consent tool

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.

Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legally authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may also appeal the decision we make on your request by using the contact information below. When you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.

8. Your privacy rights (for individuals in the United Kingdom or European Economic Area)

If you live in the European Economic Area (EEA) or the United Kingdom (UK), you may have the following rights regarding your personal data:

Access/Data Export. You may have a right to access the personal data we process and to request it in a common portable format of our choice.
Rectification. You may request that we correct any personal data that you believe is inaccurate.
Deletion. You may request that we delete your personal data. We may delete your data entirely, or we may anonymize or aggregate your information so that it no longer reasonably identifies you.
Restriction of Further Processing. You may request that we restrict the processing of personal data under certain circumstances. For example, you may make this request if you object to our use of your personal data for particular legitimate business interests.
You may have the right under applicable law to object to any processing of personal data based on our legitimate interests or for direct marketing. If you object to processing based on our legitimate interests, we may continue processing where permitted by law. If you object to processing for direct marketing, we will stop processing your personal data for that purpose.

Individuals living in the UK and EEA are also entitled to the following information about the legal bases for the processing described in section 1, above.

Categories of individuals	Categories of personal information	Legal bases
All website users	General device, usage, and activity information	Our legitimate interests
Website users who have not opted out of our use of analytics technologies	Detailed device, usage, and activity information Approximate location information Pseudonymous analytics identifier	Your consent
Individuals who send us inquiries or other correspondence	Sender name and email address Contents of inquiries or other correspondence	Your consent Our legitimate interests

If our processing of your personal data is based on your consent, you may withdraw your consent by contacting us using the information above.

If you are dissatisfied with the decision we make with regard to your request, you may appeal the decision by using the contact information above. If you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law. You also have the right to lodge a complaint with a supervisory authority.