Privacy Policy

(Date modified: 2025/11/25)

This Privacy Policy describes how Acquis Cortico-X, L.L.C. and its affiliates (collectively, “Cortico-X” or “we,” “us,” or “our”) collect, use and share personal data collected from visitors to our website (located at https://www.cortico-x.com) (our “Website”) and through our services.  By using our Website or interacting with us through our services, you acknowledge that you have read and understood this Privacy Policy. Your continued use of our Website or services constitutes your acceptance of this Privacy Policy.

Collection of Information

Identification Information.  When you interact with Cortico-X through our Website or services, you may provide or we may collect information that identifies you, such as your:

• First and Last Name
• Email
• Postal Address
• IP Address
• Gender 

Professional and employment-related information: This includes information describing your current employer, title and work history.  For example, we may collect this information when you submit a resume seeking employment with Cortico-X.

Other Information: We also collect other information you may voluntarily provide, such as when we receive your communications with us (e.g. through email, feedback, social media, filling out a web form or other forms of communication).

Information from third parties: we may also receive information about you from third party sources, including from your employer or from public record sources. For example, your employer may provide your information to us, such as in connection with our services. 

Your interactions with our website and emails: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our services, to improve the content and performance of our Website and services, and to track users’ movements around the Website. Where we link this automatically-collected data to personal information, we will obtain your consent where required by applicable law. Some of this data is collected through information sent by your web browser.  We also use cookies and other tracking technologies to collect this information. 

How do we use this information?

We use the information and data we collect principally in order to provide our Website and services.  More specifically, we may use your personal information to:

• Communicate with you regarding our services and with respect to your questions and requests, including sending you newsletters and alerts
• Operate our Website, provide our services, and publish content
• Distribute content to you in accordance with your preferences as well as provide other notifications to you (for example, updates about our policies and terms)
• Measure usage of the Website
• If you provide us with a resume or other information related to a job opening, we will use that information to evaluate your submission
• Provide for the safety and security of our Website and services
• Conduct research and similar activities to improve our Website and services
• Comply with our legal and regulatory responsibilities and enforce our rights
• In any other way we may describe when you provide your information
• For any other purpose with your consent
• Your information may be shared with third-party service providers who support our business operations, including professional advisors, web-hosting providers, analytics providers, customer-relationship management software providers and other similar information technology providers. These service providers are contractually bound to protect your personal information and may only use it for the specific services they provide to us, in accordance with our written data processing agreements and applicable data protection laws. Our list of subprocessors can be found here.
• Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
• To our affiliated entities and in connection with the sale, assignment or other transfer of our company or one of our businesses and of their assets.
• To any other third parties where you have provided your consent.

Subprocessors

How We Protect Your Information

Cortico-X implements and maintains appropriate technical and organizational security measures designed to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions. While we strive to protect your personal information, you should understand that no Internet transmission is ever 100% secure or error-free, and you provide your information at your own risk.

Children’s Information

Our Website and services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or services and click a link to another site, you will leave our Website and this Privacy Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites.

Use of Google’s reCAPTCHA

In order to fight spam and abuse on our website, we have implemented reCAPTCHA and the use of reCAPTCHA is subject to the Google Privacy Policy and Terms of Use.

Information for European Residents

• Our Legal Basis for Processing: In most instances, we process your personal information in order to perform our contractual obligations.  Please see Article 6(1)(b) of the E.U. General Data Protection Regulation (“GDPR”). For example, we rely on this legal ground when we use your personal information to administer our relationship with you or your employer in connection with our services. We may also process your personal information in connection with our legitimate interests; for example, in order to market our services to you and to understand and improve our Website, to process your information in connection with job inquiries, and where necessary to protect or defend our or another’s rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. (GDPR Article 6(1)(f)). In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)) or where you consent to such use (GDPR Article 6(1)(a)). Please see the “Your Rights” section of this Privacy Policy below for more information about how you may request that we limit or refrain from processing your personal information.
• Transferring Your Personal Information Internationally: If you are a resident of the European Union or the United Kingdom (“UK”), your information may be transferred both within and outside the European Economic Area (“EEA”) and the UK (including to the USA). When we transfer your personal information outside the EEA or UK, we will put in place appropriate safeguards in accordance with our legal obligations. These safeguards include Standard Contractual Clauses approved by the European Commission and/or UK authorities, and other appropriate safeguards as required by applicable data protection laws, to ensure that your personal information receives an adequate level of protection when transferred outside the EEA or UK.

Your Rights

• Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
• Right to Correct Information:  You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
• Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing our Privacy Team.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that Cortico-X does not use “automatic decision making” or “profiling” as those terms are defined in the GDPR.

• Timeframe for retaining your personal information: We will retain your personal information for no longer than is necessary for the purposes for which it was collected and processed. Specific retention periods vary depending on the type of information and applicable legal requirements. We maintain and follow a data retention schedule with specific retention periods for different categories of personal information based on business necessity and legal requirements. These retention periods are available upon request. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Our website is hosted by Bluehost, Inc., a Newfold Inc. company. All data collected during visits to our website is stored on Bluehost’s servers. We have entered into a Data Processing Agreement with Bluehost in accordance with applicable data protection laws. You may access Newfold’s Privacy Policy at https://www.newfold.com/privacy-center/

How to Exercise Your Rights

If you are a California resident, you may submit a request by emailing your request to Privacy.

Your ability to access, limit use and disclosure

You may request access to your personal data to update, correct or delete, or to limit the use or disclosure of your personal data.

Individuals wishing to view, update, delete, or supplement their personal data may do so by contacting the business that provided Cortico-X your personal data directly to make your requests, or alternatively you can submit your request through our Data Subject Access Request (DSAR) Portal. If the Cortico-X DSAR portal is unavailable, requests can be sent to Privacy@Cortico-X.com. Individuals outside the EU may also use the DSAR portal to submit complaints about your privacy and our collection or use of your personal information.

Do-Not-Track

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.  This is a different signal than Universal Opt Out signals, which do not apply to Cortico-X’s processing of information, because Cortico-X does not “sell” or “share for consideration” personal information. For more information about our use of cookies and similar technologies, please see our Cookie Notice below.

Social Media Features

Our Website may include social media features, including from Facebook, X (formerly Twitter) and LinkedIn. These features may collect your IP address, which page you are visiting on the Website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them.

Cookie Notice

When visiting a Cortico-X Website, we may use cookies on or in connection with our Website to maintain information about you. A cookie is a very small text document, which often includes an anonymous unique identifier and additional information necessary to support the site’s intended functionality. Cortico-X uses session cookies. A session cookie is temporary and disappears after you close your browser.

Technologies such as cookies, beacons, tags and scripts are used by Cortico-X and our marketing partners, analytics providers, and customer support systems. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and gathering demographic information about our user base. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies for marketing and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited, and you may not be able to participate in market research surveys without essential and functional cookies enabled .

Most web browsers can be set to tell you when a cookie has been sent to you and give you the opportunity to refuse that cookie.

Refusing a cookie may in some cases prevent you from using or negatively impact the display or function of our Website or certain areas or features of our Website. There are numerous resources on the Internet that can provide more information about how cookies work and how you can manage them.

The following chart details the browser cookies that are in use by Cortico-X.com.

Advantages of cookies are:

• Remembering the details provided by the user
• Remembering user preferences
• Improving the site’s effectiveness

Blocking/Restricting Cookies

To manage or delete cookies on your browser or on a mobile device, please visit either https://allaboutcookies.org/ or the official webpage of the browser or device manufacturer and the documentation provided by them and follow their instructions.

Please note, however, that disabling cookies might affect your online experience and/or prevent you from taking full advantage of our site and some of its functionality.

Cookie Notice Changes

Our Cookie Notice may change at any time. If our information practices change in a significant way, we will post the policy changes here. This Cookie Notice was last updated November 24, 2025.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Privacy Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and services following such changes, you will be deemed to have agreed to such changes.

Contacting Acquis Cortico-X, L.L.C.

If you have any questions about this Privacy Policy, the practices of our Website (www.cortico-x.com), your dealings with our Website or services, or to exercise any of your privacy rights, including accessing, correcting, or deleting any information you have provided to us, please contact Privacy. You may also contact us by mail at: 10101 w. Innovation Drive, Suite 100, Wauwatosa, WI  53226.

US Regional Privacy Notice

This Notice explains how we, Acquis Cortico-X LLC (“Cortico-X”), collect, use, and disclose your Personal Information. It also describes how to exercise your rights under the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Massachusetts Information Privacy Act, the Nevada Privacy of Information Collected on the Internet from Consumers Act, the New York Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act. We call these laws collectively the “U.S. Privacy Laws.”

When we say “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly. Personal Information does not include information that cannot be reasonably linked to you.

How we collect, use, and disclose Personal Information

To provide the products or features offered by Cortico-X we process information about you, including Personal Information, whether-or-not you have an account or are logged in. To learn about the types of information we collect and how we use it, you can review our Privacy Policy.

Subject to the limitations we describe in our Privacy Policy, we may disclose your Personal Information for business purposes, with strict restrictions on how our partners can use and disclose the data we provide. We may also disclose it at your direction or in other ways that are in accordance with the U.S. Privacy Laws. We don’t “share” your Personal Information, as defined in the California Consumer Privacy Act (“CCPA”).

Cortico-X does not sell, rent, or lease your personally identifiable information to third parties, nor does Cortico-X derive any part of our revenue or receive any discounts or compensation from such sales.

 We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or research panels; and
• Facilitation in the delivery of our Services to our clients.

Consumer’s Rights

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights:

• Right to Correct: You have the right to request the correction of any inaccurate personal information that we maintain about you, considering the nature of the personal information and the purposes of the processing of the personal information.   We will use commercially reasonable efforts to correct the inaccurate personal information as you may direct.
• Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
• Right to Opt Out: The right to opt out of the processing of your Personal Information that have obtained from or about you.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
• Do Not Track: Cortico-X does not track its customers over a period or across third-party websites to provide targeted advertising and, therefore, does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on Cortico-X websites such as a social feature may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific Company website from a certain IP address. Third parties cannot collect any other personal information from Company’s websites unless you provide it to them directly.

To submit a request to exercise your rights, and as applicable, to appeal a consumer rights action, please visit our Data Subject Access Rights Portal or email us at privacy@cortico-x.com.

If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name and email address) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information if we cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided in the U.S. and will be hosted on U.S. servers, and you authorize Cortico-X to transfer, store and process your information to and in the U.S., and possibly other countries. 

Security

To help protect the privacy of data and personally identifiable information you transmit through use of this site and any other related services, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees in terms of the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

A copy of our written Information Security Plan is available upon request – contact us to request a copy.