Float Financial Solutions US Privacy Policy

Last Updated: December 19, 2022

Introduction

Float Financial Solutions Inc. and its subsidiary Float Financial Solutions US Inc. (“Float”, “Us”, “Our”) have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information, including personal information that we collect through floatcard.com (the “Website”) and information we process on behalf of our customers in connection with the use of our Services (as defined below).

Your privacy is important to us. To ensure you have access to all of the information you need, we have laid out an overview of the content of this Privacy Policy below. If you have any questions about how we process your personal information or suggestions on how we can improve, please reach out to our Legal Team at legal@floatcard.com. If you do not agree, do not use the Float Services or Website and Product.

The information we collect, process, and otherwise receive through your use of our Product is governed by terms of our agreements with our partner institutions and customer in question, including our cardholder agreement. In the event of a conflict between this Privacy Policy and the terms of any agreements between a business customer and Float, the terms of those agreements will take precedent.

Table of Contents

1. Collection and use of Personal Information
2. Information collected through automatic data collection technologies
3. How we Use the Information we Collect
4. How we Share your Personal Information
5. Other Important Information About Your Personal Information, Safeguards and Retention
6. Your Choices About Your Personal Information
7. Additional Disclosures
8. Children under the Age of 13
9. Contact Us

Collection and use of Personal Information

Float provides an online spend management platform through which our customers can load funds onto prepaid corporate cards (“Card(s)”), set rules and budgets for expenditures made using those cards, track spending by individual employees, and manage and track business spending, through which Float can calculate cashback each customer has earned through their expenditures and derive insights for our customers on employee spending patterns (collectively the “Services”). In the course of providing these Services, we receive and process personal information as described below to provide the Services to our customers. All personal information collected or derived from an employee may be shared with our customer that issued credit cards to those employees. We do not use this information for any other purpose except as set out in this privacy policy, customer’s agreement with us, or as required or permitted by applicable laws.

• Information required to provide the Services:  In order to provide the Services to our customers, we collect, process, and disclose:
  1. Personal and Authorized User Information: Including names, titles, and email addresses of employees to whom our customers have issued credit cards. Information provided about any users who will be issued a Card, such as their name, email address, social security number (if required), forms of ID (e.g. Driver’s License or Passport) and phone number. Where information about other users is provided, you agree that you have the necessary rights and permissions to provide such information to Float.
  2. Business Information: Including your company name, incorporation documentation, size, and postal address.
  3. Account Information: We collect and use customer information in order to create an account that can be used to access and use the platform for our Services. This information includes customer name, billing address and other business contact information (email addresses, phone numbers), as well as a username and password that you create. We use this information to create and administer user accounts, authenticate users, process payments, and manage access and control rights. We ask that you do not disclose your password to anyone, and you are responsible for keeping your password confidential. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.
  4. Booking a Demo: If you request a free consultation or demo, we may collect your name, job title, and business contact information (including company email and phone number), and certain information about your company. We use this information to contact you and otherwise facilitate or provide you with your consultation or demo.
  5. Platform Use: We may monitor use of the platform by our customers’ employees or other authorized users in order to detect, investigate or prevent any actual or potential violation of our terms and conditions. We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the platform and to improve our Services.
  6. Information related to an ACH payment: If you fund your account from a US-based bank using the Automated Clearing House (ACH) network, we will collect information in line with the operating rules and requirements as defined by the National Automated Clearing House Association (NACHA).
  7. Transaction Information: Including purchase details (such as amount, frequency, and date), receipt information, and information provided to us by the card network.
  8. Content Information: Including content within messages you send to Float, such as through Sales, Support, or your account manager.
  9. Support Information: We may collect certain information (such as name, email address and nature of the inquiry) when we provide user support by phone, email or within the platform.
  10. Employment: If you apply for a job with us, we may collect certain personal information about you (such as information that would be contained in a resume, cover letter, or other employment-related materials). We use this information for the purpose of processing, evaluating and responding to your application.
  11. Surveys: From time to time, we may offer our customers the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Website.
  12. Contact Us: When you contact us with a comment, question or complaint through email, telephone, or the Website, you may be asked for information that identifies you, such as your name, email address, and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.
  13. Referral Information: When you provide potential referrals to Float, you agree that you have all rights and permissions necessary to provide such information to us.

Information collected through automatic data collection technologies

In addition to the sample of data points we highlighted in the “Collection and use of Personal Information” section above, we also automatically collect data via our Website to improve functionality, increase security, protect against fraud, understand your preferences, market to you, and better tailor our Services. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, as described in this section.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For information about how you can opt out of behavioral tracking from many providers, see Choices About How We Use and Disclose Your Information.

• Visiting our Website: We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
• Cookies: Our Website uses a technology called “cookies.” A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.
• Web Beacons: Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Analytics: We may also use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For information about managing your privacy settings for Google Analytics, see Choices About How We Use and Disclose Your Information.
• Third Party Use of Cookies: Some content or applications on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

The Website does not respond to do not track signals.

How we Use the Information we Collect

We collect and process information in accordance with the practices described in this Privacy Policy in order to action business functions, including:

1. Providing Float’s Service: We use the data we collect to allow our customers to access the platform, determine the eligibility of our customers to use our Services, to provide our Services, and to implement improvements to our offering.
2. Communicating with our Customers: We use the information we collect to send customer communications, including but not limited to, important feature announcements, marketing and advertising, security updates, and changes to our policies.
3. Security and Fraud Detection: We use the information we collect to detect and prevent fraudulent or otherwise unauthorized behavior.
4. Response to Requests: We use the information we collect to respond to customer requests that pertain to their businesses’ Float accounts.
5. With Notice to You and Your Consent: We may otherwise use the information we collect after providing sufficient notice as governed by applicable laws and regulations.
6. Compliance: We use the information to ensure compliance with legal requirements and practices.
7. Legal Rights: We use the information to protect our legal rights to the extent authorized or permitted by law.
8. De-identifying Information: We may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by law or contractual obligation applicable to us.
9. Marketing: As part of this process, we may incorporate tracking technologies into our own Services (including our Website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and Services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

. See the “Your Choices About Your Personal Information” section below for more information about your choices in connection with how we use your Personal Information.

How we Share your Personal Information

We do not sell or disclose personal information to third parties without your consent, except as set forth below or as required or permitted by law.

• Service Providers: Personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website and our platforms, and providing payment processing, authenticating users, advertising, and marketing services. Personal information that we process on behalf of customers in the course of providing the platform services will be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as issuing credit cards, loading funds and processing payments, integrating with and withdrawing funds from company bank accounts, scanning and managing receipts, hosting the Website, authenticating users, and providing advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.
• Third-Party Applications: Customers may choose to export their transaction data or other personal information to third-party applications with whom the customer has a relationship, including tax management and filing services. Customers may also choose to login to Float using a third-party application (e.g. OKTA). If a customer chooses to utilize an integration to facilitate logging into the platform, Float may receive information from the other service that you have authorized to share with us. The other service may also independently collect information for which Float holds no liability or responsibility. We encourage you to read the respective Privacy Policies of these providers. Float will share personal information with such third parties as instructed by the customer.
• Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may provide personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
• Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Float Financial Solutions Inc. or as part of a corporate reorganization or other change in corporate control.
• Subsidiaries and Affiliates: We may disclose personal information that we collect or you provided as described in this privacy policy to our subsidiaries and affiliates.

Please note that Float is not responsible for the Privacy practices of any third-party affiliates or service providers. The information collected and stored by said parties is subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or in other jurisdictions. We strongly suggest that you review the privacy practices of said parties prior to using their services.

Other Important Information About Your Personal Information, Safeguards and Retention

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. However, please note that no information security program or transfer via the internet is entirely secure and, although we employ safeguards to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, platform, or through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or platform.

• Third Party Links: Our Website may contain links to other websites that Float does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Your Choices About Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website, here. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Google Analytics. Google Analytics operates cookies on the Website. You can learn more information about how Google Analytics uses Cookies or other tracking technologies on the Platform by visiting: How Google Uses Information From Sites or Apps .  Further, you can manage your Google ad settings, by visiting: Google’s My Ad Center.
• Promotional Offers from the Company. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us after you unsubscribe.
• Unlinking Applications: If a customer has linked a third-party service, such as an accounting software or Slack, the customer may unlink their service at any time through the settings page in the Float account. Unlinking your account will not impact data collected while the services were connected. The other service may also independently collect information for which Float holds no liability or responsibility. We strongly suggest you to read the respective privacy policies of these providers.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, here.

Access to information

If we receive a request from an individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests. Subject to applicable law, you may have the right to access, update and correct inaccuracies in your personal information in our custody or control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

Additional Disclosures

Nevada Residents: Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at legal@floatcard.com.

Children’s under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website or receive our services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website, If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the information provided in the “Contact Us” section of this privacy policy.

Contact Us

If you have any questions or comments about this privacy policy or the manner in which we or our service providers treat your personal information, or to request access to our collection of your personal information, please contact us at:

+1 (833) 944-3175

legal@floatcard.com 

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