Privacy policy.

Float, LLC (“Float,” “we,” “us”), respects the privacy of individuals who visit our website (“Visitors”) and individuals who use our mobile applications or register to use our services on behalf of Float’s clients (“Users”). This Privacy Policy describes our practices regarding the collection, use, processing, protection, and disclosure of Personal Information, as well as the rights available to individuals under applicable law.

This Privacy Policy applies to Personal Information that is provided to or collected through our website, www.gowithfloat.com (“Website”), our mobile application SparkLearn® (“Apps”), and the services we provide through the Website and Apps (collectively, the “Services”).

Use of Personal Information collected through the Services is limited to providing the Services for which the Visitor or User engaged Float and as described in this Privacy Policy.

Float, LLC complies with the EU–U.S. Data Privacy Framework (EU–U.S. DPF), the UK Extension to the EU–U.S. DPF, and the Swiss–U.S. Data Privacy Framework (Swiss–U.S. DPF) as set forth by the U.S. Department of Commerce. Float has certified to the Department of Commerce that it adheres to the DPF Principles for Personal Information transferred from the European Union, United Kingdom, and Switzerland to the United States. If there is any conflict between this Privacy Policy and the DPF Principles, the DPF Principles govern.

To learn more about the DPF program and to view our certification, please visit:
https://www.dataprivacyframework.gov

“Personal Information” means information about an identified or identifiable individual consistent with EU, UK, and Swiss data protection definitions, provided to Float from the EU, United Kingdom, or Switzerland.

A. Who We Are

Float mobilizes people, processes, and software in high-performing organizations through the design and development of digital tools, custom applications, and human-centered learning experiences. We develop responsive Websites and Apps that are accessible across devices to support the delivery of our Services.

B. Collection & Use of Personal Information

Float follows this Policy to protect your privacy. We do not collect more Personal Information than necessary to provide the Services; we use Personal Information only for the purposes described in this Privacy Policy or with your consent; we retain Personal Information only as long as necessary; and we share Personal Information only as described in this Privacy Policy.

1. What Information We Collect & How It Is Used

The Personal Information we collect depends on your interaction with the Services and may include:

  • Name, email address, phone number, company name, and contact details

  • IP address, device identifiers, and browser information

  • Account login credentials

  • User activity and training progress within employer programs

  • Diagnostic and analytics data, including error reports

We collect Personal Information when you:

  • Correspond with us

  • Visit our Website, install our Apps, or use our Services

  • Register as a User or when your employer creates an account for you

  • Contact us for help or support

  • Attend conferences or webinars

  • Interact with analytics features in our Website or Apps

We use Personal Information to:

  • Deliver and manage the Services

  • Provide customer support and manage client relationships

  • Improve and develop our services and user experiences

  • Analyze usage patterns and performance

  • Communicate regarding Float or third-party offerings

  • Enforce our terms and conditions

  • Fulfill other purposes disclosed at the time of collection

2. Information Specific to Our Websites and Apps

If you contact us through our Website or Apps, we collect any information you choose to provide for the purpose you provided it.

Most Apps require registration. Information collected may include your name, email address, business title, and training progress. Employers may receive reports of User progress within employer-managed programs.

Float may collect, store, aggregate, and analyze de-identified or aggregated usage data for analytics, service improvement, and product development. This data does not identify you.

We use cookies to understand site usage, personalize content, and improve our offerings. You can manage cookie preferences through your browser settings.

3. Information Specific to Recruitment

If you apply for a job with Float, we collect information you provide during the recruitment process. We may retain some information to consider you for future opportunities. We do not sell or rent recruitment-related data.

We disclose Personal Information when required by law or government authorities, including to meet national security or law enforcement obligations.

4. Information Specific to Employees and Independent Contractors

Float collects Personal Information from employees and independent contractors (“ICs”) for legitimate business purposes, including HR administration, payroll, benefits, performance management, and general business operations.

Only designated Float personnel may access such data. EU, UK, and Swiss HR data is processed solely for employment-related purposes, in accordance with DPF requirements.

We may disclose employee or IC Personal Information:

  • To HR service providers retained by Float

  • When required by law or in response to lawful governmental requests

  • When voluntarily provided by employees or ICs for use with third-party systems such as payroll, benefits, or travel services

Float cooperates with the EU Data Protection Authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) regarding HR data transferred under the DPF.

5. How We Protect Your Information

Float maintains appropriate administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. Payment information, where applicable, is encrypted. Users are responsible for maintaining the confidentiality of account credentials.

6. Retention of Personal Information

Float retains Personal Information only as long as necessary to fulfill the purpose for which it was collected, including complying with legal obligations, resolving disputes, and enforcing agreements. Retention periods vary based on data type and applicable laws.

C. Sharing of Personal Information & Accountability for Onward Transfer

Float engages a limited number of third-party service providers (“agents”) to assist with hosting, storage, analytics, and operational support. These providers may access or process Personal Information in the course of providing services to Float and are contractually bound to use the information only as directed by Float.

Float uses a number of service providers to help operate our Services, including:

Float complies with the DPF Onward Transfer Principle and remains responsible and liable for Personal Information transferred to third-party agents that process Personal Information on our behalf.

EU, UK, and Swiss individuals have the right to opt out of:

  • Disclosures of Personal Information to non-agent third parties

  • Uses of Personal Information for purposes materially different from the original purpose of collection

Float will not process Sensitive Personal Information without explicit opt-in consent. For purposes of the Data Privacy Framework, “Sensitive Personal Information” includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric identifiers, health information, sexual orientation, or information about criminal convictions or offenses.

Float may transfer Personal Information to the United States or other countries where Float operates. By providing Personal Information, you consent to such transfers, understanding that data protection laws may differ from those in your country of residence.

D. Access and Correction of Personal Information

Pursuant to the GDPR, EU and Swiss individuals, specifically have the right to access, correct, amend, or delete Personal Information held by Float where it is inaccurate, or has been processed in violation of this Privacy Policy. The rights granted to EU and Swiss individuals under the GDPR more specifically includes such rights to:

  • Update Your Personal Information: If you would like to update Personal Information that you have provided to us, please send an email to us as indicated in Section E.

  • Marketing Communications: You can opt-out of receiving marketing communications from Float by clicking “unsubscribe” in any marketing email communications we send to you.

  • Right not to provide consent or to withdraw consent: We may seek to rely on your consent in order to process certain Personal Information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.

  • Right of access: You may have the right to access the Personal Information that we hold about you.

  • Right of erasure: In certain circumstances, you may have the right to the erasure of Personal Information that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).

  • Right to object to processing: You may have the right to request that we stop processing your Personal Information and/or to stop sending you marketing communications.

  • Right to correct: You may have the right to require us to correct any inaccurate or incomplete Personal Information.

  • Right to restrict processing: You may have the right to request that we restrict processing of your Personal Information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).

EU and Swiss individuals may exercise these rights by contacting our privacy officer as indicated in Section E below.

Additionally, EU and Swiss individuals no longer desiring to use our Services may deactivate the Services by contacting us as indicated in Section E below. EU and Swiss individuals may withdraw their consent to our use of their Personal Information at any time by contacting us using the contact information below, but that will mean we can no longer provide the Services to such EU and Swiss individuals. We will respond to requests regarding changes to Personal Information or Service cancellation promptly, but in any event within 30 days of the call or receipt of such requests. We may also take reasonable steps to verify the identity of individuals submitting such requests before making corrections, amendments, or deleting Personal Information and before cancelling our Services. 

Float reserves the right to refuse to comply with an individual’s request to exercise any rights listed under this Section D where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated, or there are compelling legitimate grounds to continue processing or storing the personal info, or as limited under applicable U.S. laws. 

E. Contact Information 

For questions related to this Privacy Policy, or to exercise any rights enumerated in Section E above, please contact our privacy officer at dhenderson@gowithfloat.com or at: 

Float, LLC
Attn: Denise Henderson
PO Box 289
Morton, Illinois 61550

Email: dhenderson@gowithfloat.com
Phone: (309) 263-2492
Fax: (309) 263-8262 

F. Enforcement & Liability

Float commits to resolve complaints about privacy and our collection or use of Personal Information. EU or Swiss individuals with inquiries or complaints regarding this Privacy Policy, such as to request correction, amendment, or removal of Personal Information, should first contact us as set forth in Section E above. 

If you believe (1) your personal data was collected in a European Union (EU)/European Economic Area (EEA) member country, the United Kingdom, and/or Switzerland, and (2) you believe you have a claim concern the collection, use, and retention of your personal data by FLOAT, LLC, and (3) you were not able to resolve your complaint after direct consultation with FLOAT, LLC, you may submit a claim to JAMS to open a Data Privacy Framework (DPF) for dispute resolution through its Data Privacy Framework Dispute Resolution Process. https://www.jamsadr.com/DPF-Dispute-Resolution. This independent dispute resolution mechanism is provided at no cost to EU/UK/Swiss individuals..

For HR data transferred under the DPF, Float cooperates with the EU DPAs, ICO, and FDPIC.

Float is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission (FTC).

As a last resort, EU/EEA, UK, and Swiss individuals may invoke binding arbitration under Annex I of the DPF Principles.

Float adheres to all seven DPF Principles: Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity & Purpose Limitation; Access; and Recourse, Enforcement & Liability.G. Changes to our privacy policy

G. Changes to our privacy policy

Float may update this Privacy Policy from time to time. We will post updates on this page and, when required by law, notify you or request your consent.