Float, LLC (collectively, “Float” and “We), respects the privacy of individuals who visit our website (“Visitors”), and who use our mobile applications or register to use Float’s Services (defined below) on behalf of Float’s Clients (“Users” or “Visitors”) (collectively “you” or “your”).
“Personal Information” is data about an identified or identifiable natural individual as more particularly defined under European legislation, received by an organization in the United States, specifically from the European Union or Switzerland, and recorded in any form.
A. Who We Are
Float is a company that mobilizes people, processes, and software in high-performing organizations through custom Apps, digital strategy, and human-centered design all focused on performance support. We design and develop responsive Websites and Apps you can access regardless of the device.
B. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks
C. Collection & Use of Personal Information
Float follows the Principles, in order to protect your privacy, specifically:
- we do not collect any more Personal Information than is necessary to provide the Services;
- we do not keep your Personal Information if it is no longer needed; and
1. What Information We Collect From You & How It Is Used
The type of information we collect from you depends on your interaction with our Services. The information we collect may include your Personal Information, such as your name, contact information, IP addresses, Service selections, and other things that identify you.
We collect Personal Information from you at several different points, including but not limited to the following:
- when we correspond with you as a customer or prospective customer;
- when you visit our Websites, install our Apps, and use our Services;
- when you register as a User of our Services or an account is created for you by your employer;
- when you contact us for help;
- when you attend our customer conferences or webinars; and
- when our Websites or Apps send us error reports and analytics data.
We may use information that we collect about you to:
- deliver the Services that you have requested;
- manage your customer relationship and provide you with customer support;
- perform research and analysis about your use of, or interest in, our Services, or content, or products, services, or content offered by others;
- communicate with you by e-mail, postal mail, collaboration apps, telephone and/or mobile devices about Services that may be of interest to you either from us, or other third parties;
- enforce our terms and conditions;
- manage our business; and
2. Use of Information Specific to Our Websites and Apps
If you contact us through our Websites, we collect your name, company name, email address, phone number, and any information that you choose to provide to us. We will use the data and Personal Information directly submitted by you for the purpose for which it was provided. We may also use Personal Information you provide to us to contact you for reasons related to your original communication to us and for our own business records.
Most of our Apps require Users to have registered accounts for access. You may register for an App directly or you may be registered by your employer. Personal Information required for registration may include your email address, name, and business title if appropriate. If you register for an App or you are registered by your employer, information may be collected pertaining to your progress in employer training programs for the purposes of providing this information to your employers. Contact information from the User registration forms is used when necessary for account management, technical support, and marketing reasons related to you or your employer’s use of our Services.
We may use the Personal Information collected in connection with the development, design, marketing, or quality improvement of our Services. Float collects, stores, aggregates, analyzes, and discloses anonymous and de-identified usage data, which includes data regarding your use and configuration of Float software. Such data will not identify your Personal Information and you hereby assign to Float any and all rights in and to such data, including all copyrights, patent rights, and all other intellectual property rights thereto.
3. Use of Information Specific to Recruitment
If you apply for a job with us, we will collect, process, and store the information you provide to us for recruitment purposes. We may also retain some of your Personal Information for a reasonable period of time for purposes of considering you for future positions.
We will release Personal Information as required in response to lawful requests by public authorities, and to meet national security or law enforcement requirements.
4. Use of Information Specific to Employees and Independent Contractors
We may collect Personal Information from prospective and present employees as well as from independent contractors (“IC(s)”), as applicable, only for legitimate business purposes, including maintaining company records, contracting with the individual, the administration of employee health insurance and other employee benefits. Our EU and Swiss employees and ICs at the time of their engagement will be notified in detail how their Personal Information will be used. Employees’ and ICs’ Personal Information on applicable health, performance evaluations, disciplinary actions, and other sensitive business matters, whether it is stored manually or ectronically, is accessible only by designated Float personnel if necessary for legitimate business purposes; however, an employee’s or IC’s picture and any information the employee or IC chooses to provide may be placed on the Float server. Likewise, from time to time, an employee’s or IC’s picture along with Personal Information may be published in the Float directories, internal websites, and used in presentations.
For legitimate business purposes, employees and ICs may choose to voluntarily disclose Personal Information about family members. If our employees or ICs choose to do this, their family member’s Personal Information shall be treated, for the purposes of this Policy, the same as an employee’s or IC’s Personal Information. Employees’ and ICs’ Personal Information is never sold, leased, or rented to any third party.
Employees’ and ICs’ Personal Information will never be disclosed to third parties, except as follows:
- to those retained by Float for processing only for the purposes set forth below;
- where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of Float;
- where authorized electronically or in writing by the employee or IC; and
- where the employee or IC voluntarily provides Personal Information and the context makes it clear that Personal Information will be provided to a third party/subprocessor (e.g., payroll, benefits, travel, reimbursement, and other systems used in the engagement context).
Where Personal Information is transferred from the EU or Switzerland to the U.S. in the context of the employment relationship, we will cooperate in investigations by and comply with the advice of the EU Data Protection Authorities (DPAs) and Swiss Federal Data Protection and Information Commission (FDPIC).
5. How We Protect Your Information
Taking into account the risks involved in the processing and nature of Personal Information and to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction, while maintaining data accuracy, Float has put in place appropriate physical, electronic, and managerial policies and procedures to safeguard the Personal Information Float collects. Any payment transactions will be encrypted using SSL technology. However, the safety and security of your information also depends on you. Where you have chosen or we have given you a user name and password for access to certain parts of our Services, you are responsible for keeping the user name and password confidential. Thus, it is important that you DO NOT SHARE YOUR USER NAME AND PASSWORD WITH ANYONE.
6. Retention of Personal Information
We will retain your Personal Information for only as long as it serves the purposes for which it was collected and will be retained in a form identifying you or making it identifiable to you only for as long as it serves the purpose for which it was provided. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
D. Sharing of Personal Information & Accountability for Onward Transfer
Float uses a number of service providers to help operate our Services, including:
You have the choice to limit the use and disclosure of your Personal Information by simply not providing that information to us. In certain cases, limiting the use and disclosure of your Personal Information may impact functionality or prevent the use of Float’s Services.
Wherever you use our Services, you understand and acknowledge that we may transfer, process, and store Personal Information about you in the U.S. and other countries, both within and outside of the EU and Switzerland. By providing us with your Personal Information, you consent to the transfer to, and to the processing and storage of your information in, countries outside of your country of residence, which may have different data protection laws than those in the country in which you reside.
E. Access and Correction of Personal Information
- 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 F.
- 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 F below.
Additionally, EU and Swiss individuals no longer desiring to use our Services may deactivate the Services by contacting us as indicated in Section F 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 E where: the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, the rights of persons other than the individual would be violated, there are compelling legitimate grounds to continue processing or storing the personal info, or as limited under applicable U.S. laws.
F. Contact Information
Attn: Privacy Officer
620 West Jackson Street
Morton, Illinois 61550
Phone: (309) 263-2492
Toll Free: (877) 903-5628
G. Enforcement & Liability under the Privacy Shield Framework
- Non-Human Resource Data. If your first complaint is not satisfactorily addressed by Float, and your inquiry or complaint involves non-human resource data, Float has further committed to refer unresolved non-human resource Privacy Shield complaints to Judicial Arbitration and Mediation Services, Inc (“JAMS”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your non-human resource complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.
- Human Resource Data. If your first complaint is not satisfactorily addressed by Float, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU individuals, a panel established by the EU DPA Panel, and for Swiss individuals, the FDPIC. To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Float agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC. The services of EU DPAs and the FDPIC are provided at no cost to you.
Please note that if your complaint is not resolved through any of the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.