INFORMATION WE COLLECT
When you interact with us through the Service, we may collect Personal Data and other information from you, as further described below:
Non-Identifiable Data: When you utilize the Service, we may receive certain personally non-identifiable information about your use of the Service. 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, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to the Service, the number of visitors to each page of the Service, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
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 Data 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.
OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION
We use information to help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm CounterFactual.AI, our users, or the public. When we detect spam, malware, illegal content, and other forms of abuse on our systems in violation of our policies, we may disable your account or take other appropriate action. In certain circumstances, we may also report the violation to appropriate authorities.
We may communicate with you through email and notices posted via the Service. These communications may include a series of welcome emails that help inform you about various features of the Service. Please be aware that you may receive certain emails from us related to the proper functioning of your account. We, along with your Lab Sponsor and their affiliates, may send you promotional information unless you have opted out of receiving such information. If you wish to opt-out of receiving promotional emails, please click the “unsubscribe” link at the bottom of the email or send us a communication using the contact information below.
OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION
There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, including as set forth below:
With your consent: We will share personal information with companies, organizations or individuals outside of CounterFactual.AI when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
Service Providers, Agents and Related Third Parties: We may hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. If we employ another company to perform a function of this nature, we may need to provide them with access to certain Personal Data.
Lab Sponsors, Business Partners and Related Third Parties: We may enter into agreements with business partners and other third parties to make the Services available to you. For example, our Service may be provided to you in conjunction with a Lab Sponsor and/or its affiliates. Accordingly, we may share with such business partners and third parties, including any Lab Sponsor and/or affiliates, information including Personal Data so the business partner or other third party can effectively work with us to manage or operate the corresponding Service or otherwise make the Service available for your use.
Legal Requirements: We may also disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (iv) protect against legal liability.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business, assets relating to the Service, including Personal Data, may be part of the transferred assets.
MANAGING AND DELETING YOUR INFORMATION
Reviewing, and Updating Your Information
When you’re signed in with your CounterFactual.AI account, you can always review and update information by visiting your account profile.
Exporting, Removing & Deleting Your Information
You can export a copy of content in your CounterFactual.AI account if you want to back it up or use it with a service outside of CounterFactual.AI by contacting us. You may update, correct, or delete your profile information and preferences at any time by accessing your profile page or editing your CounterFactual.AI profile through the Services.
You can also delete your labs by using the available tools in our Services. If desired, you can delete your entire CounterFactual.AI account, including all information associated with your account such as lab and quest progress, class history, and badges earned by choosing that option in your account settings page.
Please note that while your deletions are reflected promptly in active member databases, in some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes. See “Data Retention” below for more information.
There are other ways to control the information CounterFactual.AI collects whether or not you’re signed in to a CounterFactual.AI account, including configuring your browser to indicate when CounterFactual.AI has set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. But remember that our Services rely on cookies to function properly.
Information Retained Until You Remove It
As we describe above, you can delete your entire CounterFactual.AI account, including all information associated with your account such as lab and quest progress, class history, and badges earned by using the available tools in our Services. In some cases, rather than provide a way to delete data, we store it for a predetermined period of time. For each type of data, we set retention timeframes based on the reason for its collection.
Information Retained For Extended Time Periods for Limited Purposes
Sometimes business and legal requirements require us to retain certain information for specific purposes for an extended period of time. Reasons we might retain some data for longer periods of time include:
Security, fraud & abuse prevention
Complying with legal or regulatory requirements
Ensuring the continuity of our services
When you sign up for the Service, we ask you to provide Personal Data. If you do not wish to provide such Personal Data, you may not use the Service. If we want to use Personal Data in a manner different than the purpose for which it was collected, we will ask for your consent prior to doing so. If we propose to use Personal Data for any purposes other than those described in this Policy and/or in the specific notice provided through the Service, we will offer you an effective way to opt out of our use of your Personal Data for those other purposes.
LINKS TO OTHER WEBSITES
We take reasonable steps to protect the Personal Data provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These steps include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store Personal Data. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to us via the Internet.
COMPLIANCE & COOPERATION WITH REGULATORS
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
If European Union (EU) data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service. Please contact us to exercise these rights.
If you have any questions, you may contact us. If you have concerns regarding your rights under local law, you can contact your local data protection authority. CounterFactual.AI has appointed Rossy Consulting EMEA Ltd. to act as its local representative under Article 27 of the EU General Data Protection Regulation. Rossy Consulting EMEA Ltd. address is Kettenbrückengasse 5, Büro 529, Wien 1050, Österreich
With your consent
We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.
When we’re pursuing legitimate interests
We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
Providing, maintaining, and improving our Services to meet the needs of our users
Developing new products and features that are useful for our users
Understanding how people use our Services to ensure and improve the performance of our Services
Customizing our Services to provide you with a better user experience
Marketing to inform users about our Services
Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services
Protecting against harm to the rights, property or safety of CounterFactual.AI, our users, or the public as required or permitted by law
Performing research that improves our Services for our users and benefits the public
Fulfilling obligations to our partners like lab sponsors
Enforcing legal claims, including investigation of potential violations of our Terms of Service
When we’re providing a service
We process your data to provide a service you’ve asked for under a contract. For example, we process your information in connection with labs and trainings provided by your Lab Sponsor.
When we’re complying with legal obligations
We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.
ACCESS TO INFORMATION
We strive to keep your Personal Data accurately recorded. Through the Service, we provide you with access to update your profile and revise Personal Data previously submitted to the Service.