[Draft and subject to change] — this document is published in draft, pending legal counsel review, and may be revised.
Keel

Bank-Connection (Plaid) Disclosure

[DRAFT AND SUBJECT TO CHANGE]

This disclosure is published in draft form and may be revised. It is under

review by legal counsel and is effective as written until superseded.

Status: Draft, subject to change

Owner: Keel (also operating as KeelManager) — the platform provider

Last updated: 2026-07-23

1. About this disclosure

The Keel platform (KeelManager, at keelmanager.com) offers an optional

bank-connection feature that lets an authorized administrator link a fund's bank

account to power transaction reconciliation. To provide it, Keel uses Plaid Inc.

("Plaid") as its data-aggregation provider. This disclosure explains that flow. It is

read together with our Privacy Policy.

Keel provides this feature as the software provider on the tenant's behalf; the

tenant firm decides whether to enable it and which accounts to connect.

2. What happens when an account is connected

  • When an administrator connects a bank account, Plaid securely collects the login

credentials directly — Keel never sees or stores your online-banking username or

password.

  • Plaid returns to Keel an access token plus account and transaction data (such as

balances, transaction amounts, dates, and descriptions) for the connected account.

  • Keel uses that data only to display the bank ledger and to reconcile transactions

against capital-call payments and distributions within the platform.

3. How the data is used and protected

Bank-connection data is treated as sensitive and is protected with the safeguards

described in our Privacy Policy and

Information Security Policy, including encryption and

role-based access. Keel does not sell this data and does not use it for advertising.

4. Your consent and control

Connecting an account is optional and requires the administrator's explicit action. Your

use of Plaid is also governed by Plaid's own end-user privacy policy. A connected account

can be disconnected at any time, after which Keel stops retrieving new data from it and

retains prior records only as required for financial-record, audit, and legal purposes.

5. Contact

Questions about the bank-connection feature can be sent to privacy@keelmanager.com.