CounterFactual.AI LLC ("CounterFactual.AI") is committed to upholding the highest ethical standards in its business practices and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. This Privacy Shield Policy sets forth the privacy principles that CounterFactual.AI follows with respect to personal consumer information transferred from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and Switzerland to the United States.

This Privacy Shield Policy applies to all Personal Information received from consumers by CounterFactual.AI in the United States from the European Economic Area and Switzerland, in any format including electronic, paper or verbal.

CounterFactual.AI complies with the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland. CounterFactual.AI has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Privacy Shield program, and to view our certification page, please visit

The Federal Trade Commission has jurisdiction with enforcement authority over CounterFactual.AI’ compliance with the EU-US Privacy Shield Framework.


For purposes of this Privacy Shield Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses Personal Information under the instructions of, and solely for CounterFactual.AI or to which CounterFactual.AI discloses Personal Information for use on CounterFactual.AI’ behalf or in partnership with CounterFactual.AI. Examples of Agents may include service providers and related third parties that CounterFactual.AI may hire to perform certain business-related functions. Other examples of Agents may include lab sponsors, business partners and related third parties with which CounterFactual.AI may enter into agreements to make its services available to users.

“Personal Information” means any information or set of information that identifies or is used by or on behalf of CounterFactual.AI to identify an individual. This includes first name, last name, email address and company name. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information. We use this information to give the individual access and personalization to the CounterFactual.AI service.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, CounterFactual.AI will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.


When you interact with us through the services provided by CounterFactual.AI, including the website(s) we operate (the “Services”), we may collect the following types of Personal Information and other information from you, as further described below. This information is being collected under the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Frameworks. We will collect and use the information for the purposes noted below.

Personal Information That You Provide Through the Services: We collect Personal Information from you when you voluntarily choose to provide such information such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain features of the Services. If you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide access to such Services and to monitor your use of such Services. Also, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem. We may also use your Personal Information and other information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. We may also use this information to contact you in the future to tell you about services we believe will be of interest to you.

Non-Identifiable Data: When you utilize the Services, we may receive certain personally non-identifiable information about your use of the Services. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information ourselves or it may be included in databases owned and maintained by our affiliates or Agents. We may use such information and pool it with other information to track, for example, the total number of visitors to websites providing the Services, the number of visitors to each page, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Information is available or used in this process.

Cookies: In operating the Services, we may use cookies. A cookie is a piece of information that the computer or computers that host our Services give to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze usage of the Services more accurately. For instance, our Services may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the Services. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some features of the Services.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our end user’s demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our affiliates, Agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.


The privacy principles in this Privacy Shield Policy are based on the Privacy Shield Principles.

NOTICE: Where CounterFactual.AI collects Personal Information directly from individuals in the EEA and Switzerland, it will inform them about the purposes for which it collects and uses Personal Information about them and the choices and means, if any, CounterFactual.AI offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to CounterFactual.AI, or as soon as practicable thereafter, and in any event before CounterFactual.AI uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-Agent third party.

CHOICE: For Personal Information, CounterFactual.AI offers individuals the opportunity to choose (opt-in) whether their Personal Information is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To choose, individuals can check the box with the title “Opt-in: Send me valuable promos or updates about new hands-on learning” on the “My Account” page.

For Sensitive Personal Information, CounterFactual.AI will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

CounterFactual.AI will provide individuals with reasonable mechanisms to exercise their choices.

ACCOUNTABILITY FOR ONWARD TRANSFER: CounterFactual.AI may provide Personal Information to Agents to perform tasks on behalf of and under our instructions. Such Agents must agree to use such Personal Information only for the purposes for which they have been engaged by CounterFactual.AI.

CounterFactual.AI also may disclose Personal Information for other purposes or to other third parties when the individual has consented to or requested such disclosure. Please be aware that CounterFactual.AI may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. CounterFactual.AI remains responsible for any of your Personal Information that is shared with third parties under the Onward Transfer Principle, for external processing on our behalf.

SECURITY: CounterFactual.AI will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY AND PURPOSE LIMITATION: CounterFactual.AI will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. CounterFactual.AI will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. We will only collect and store Personal Information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request.

ACCESS AND RECOURSE: CounterFactual.AI acknowledges the right of individuals access to their personal data. Upon request, CounterFactual.AI will grant individuals reasonable access to Personal Information that it holds about them. In addition, CounterFactual.AI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by contacting CounterFactual.AI by mail at 101 South Garland Avenue, Suite #108, Orlando, FL 32801.

ENFORCEMENT AND LIABILITY: CounterFactual.AI will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Shield Policy. Any employee that CounterFactual.AI determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.


In compliance with the EU-US Privacy Shield and Swiss-U.S. Privacy Shield Principles, CounterFactual.AI commits to resolve complaints about your privacy and our collection or use of your Personal Information. EEA and Swiss individuals with inquiries or complaints regarding this Privacy Shield Policy should first contact CounterFactual.AI at You may also refer a Privacy Shield complaint to your local data protection authority and we will work with them to resolve your concern. In certain circumstances, the Privacy Shield Frameworks provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.


CounterFactual.AI's Privacy Policy, which can be found at (the “Website Privacy Policy”), contains information regarding how CounterFactual.AI collects and personal information and other information of consumers on our website generally. This Privacy Shield Policy is intended to provide additional information about our practices with respect to Personal Information that is transferred from the EEA and Switzerland to the U.S. In the event of any inconsistencies with the Website Privacy Policy and this Privacy Shield Policy with respect to such information, this Privacy Shield Policy shall govern.


Questions or comments regarding this Privacy Shield Policy should be submitted to CounterFactual.AI by mail at 101 South Garland Ave, Suite #108, Orlando, FL 32801 United States of America


This Privacy Shield Policy may be amended from time to time, with or without notice, consistent with the requirements of the Privacy Shield Principles. Please review this Privacy Shield Policy periodically, and especially before you provide any Personal Information. This Privacy Shield Policy was last updated on the date indicated above.