Float Financial Solutions Privacy Policy

Last Updated: November 2022

Float Financial Solutions Inc. and its subsidiary Float Financial Solutions US Inc. (“Float”) 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 floatfinancial.com (the “Website”) and information we processes on behalf of our customers in connection with the use of our services

Children 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.

For residents of Quebec, the above is applicable for children under 14.

Collection and use of personal information

• Information we collect and use on behalf of our customers: Float provides an online spend management platform through which our customers can load funds onto prepaid payment cards or set limits on a charge card (collectively the “Float Cards”), set rules and budgets for expenditures made using those Float Cards, and track spending by individual employees manage and track business spending. In the course of providing these services, we receive and process personal information to provide the services to our customers as described below.
• Information required to provide the Platform:  In order to provide the platform to our customers, we collect, use, and disclose personal information of individuals, including employees to whom our customers have issued Float Cards. The personal information we collect, use, and disclose includes business contact information such as name, job title, and company email address, as well as spend information (such as the type, dollar amount, and frequency of transactions). We use this information to provide spend management services on behalf of our customers, including to process and approve transactions and derive insights for our customers on employee spending patterns. All personal information collected or derived from an employee may be shared with our customer that issued Float 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.
• Transaction Data: We may collect certain information from Float Card users, such as payment amounts, Float Card number, transactions, and purchase details, amounts, and locations, as well as receipt data, which includes information that you submit to us to process your receipts, such as photos and support team messages. We use this information to operate and manage our service and the Float Cards, including preventing and detecting fraudulent or unauthorized transactions. We may also use this information to understand how our customers use the Service and Float Cards and to improve them.
• Support Services: We may collect certain information (such as name, email address and nature of the inquiry) when we provide user support services by phone, email or within the platform, including to send you technical notices, updates, security alerts, information regarding changes to our policies, and support administrative messages.
• Use of the Platform: 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.

Information we collect and use through our Website, platform, and other interactions

• Account Information:   We collect and use customer information in order to create an account that can be used to access and use the platform. 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.
• Company Data: With your consent, when you sign up for Float Cards we collect details about your company and its ownership, such as business owner name, email address, date of birth and home address, in order to comply with our legal and regulatory obligations under applicable Anti-Money Laundering legislation. When you connect your bank account via our third party partners, we collect information such as your balance, routing and account numbers, transaction history and tax identification number. When you connect your company’s accounting software to the platform, we collect details about your financial data. We use this information to operate and manage the Float Cards, including determining eligibility for the Float Cards, providing underwriting services, and otherwise providing services requested by you. We may also use this information to improve our Float Cards and services.
• 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.
• Marketing communications:  We may send you communications (including by mail and email). We collect your email address as well as other information to help us tailor communications to you regarding our platform and other products and services that we believe are of interest to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications 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.
• 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.
• 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.
• 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.

Sharing of 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 Float 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. 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 defence 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.

Information collected through automatic data collection technologies

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 behavioural tracking from many providers, see Choices About How We Use and Disclose Your Information.

The Website does not respond to do not track signals.

• 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).
• 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 more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy.”
• 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.
• 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.

Safeguards and retention

Safeguarding your personal information is very important to us. 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.   We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.  This retention process does not apply to personal information that has been aggregated or anonymized such that it does not identify you personally.

Choices About How We Use and Disclose Your 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. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• 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.

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.

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.

Updates to this privacy policy

We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.

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:

Ruslan Nikolaev
+1 (833) 944-3175
legal@floatfinancial.com

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