Privacy Policy
[DRAFT AND SUBJECT TO CHANGE]
This Privacy Policy is published in draft form and may be revised. It is under
review by legal counsel; the substance describes Keel's current, actual data
practices and is effective as written until superseded by a finalized version.
Status: Draft, subject to change
Owner: Keel (also operating as KeelManager) — the platform provider
Last updated: 2026-07-23
1. About this Policy
This Privacy Policy explains how Keel (also branded KeelManager; "Keel", "we",
"our", "us") — the provider of the Keel fund-administration and investor-portal
software — collects, uses, shares, and protects personal information. It applies to the
Keel marketing website at keelmanager.com, to Keel account sign-up and billing, and
to Keel's operation of the software on behalf of the investment firms that subscribe to
it (each a "tenant").
Keel is the software provider, not a fund manager. For the limited-partner and
prospect data a tenant enters into or generates within the platform, the tenant is the
controller (or, under U.S. financial-privacy law, the financial institution of
record) and Keel acts as its processor / service provider — we handle that data only
on the tenant's documented instructions and to operate the service. Each tenant maintains
its own privacy notice for its investors; this Policy governs Keel's own handling of
data. Where a tenant needs an investor- or prospect-facing privacy notice of its own, it
publishes that on its own admin, investor, and prospect portals.
2. Information Keel collects
2.1 Account and billing data (Keel is the controller)
When a firm signs up for Keel or an authorized administrator creates an account, we
collect: name, work email, the firm/tenant name and chosen web address, authentication
credentials (email + password or magic-link, and any multi-factor enrollment secret),
plan selection, and billing details. Keel's own subscription billing is in USD.
2.2 Tenant and investor data (Keel is the processor)
To provide the service, the platform stores and processes the data a tenant enters or
generates — for example limited-partner identity and contact details, tax identifiers,
banking/wire instructions, accreditation and KYC evidence, capital-account ledgers,
capital-call notices, and tax documents. **Keel processes this data solely on the
tenant's behalf and instructions**; the tenant determines what is collected, why, and for
how long, subject to applicable law and its own investor privacy notice.
2.3 Website, usage, and security data
Across the marketing site and the application we collect standard technical data —
IP address, device/browser information, pages viewed, and security/audit logs of
administrative actions — to operate, secure, and improve the service. Cookie use is
described in our Cookie Notice.
2.4 Bank-connection data
Where a tenant enables the bank-connection feature, account and transaction data obtained
through our data-aggregation provider is processed to power reconciliation. See the
Plaid Disclosure for details on that specific flow.
3. How Keel uses information
Keel uses personal information to: provide, maintain, secure, and improve the platform;
authenticate users and prevent fraud or abuse; process a tenant's subscription and
billing; provide support; send service and administrative communications; and comply with
law. For data processed on a tenant's behalf, Keel uses it only to deliver the service
and per the tenant's instructions — never to independently market to that tenant's
investors, and never sold.
4. How Keel shares information
Keel does not sell personal information. We share it only:
- With sub-processors that help us run the platform (for example cloud hosting and
database, transactional email/SMS, and the bank-data aggregator). Our current
sub-processors are listed in the Sub-Processors register,
each bound by contract to confidentiality and appropriate safeguards.
- With the tenant whose data it is (and its authorized personnel), which is the
purpose of the platform.
- As required by law, or to protect the rights, safety, and security of Keel, our
tenants, and their investors.
- In a corporate transaction (merger, acquisition, or asset sale), subject to this
Policy's protections.
5. Security
Keel maintains administrative, technical, and organizational safeguards designed to
protect personal information, including encryption in transit and at rest for sensitive
fields, role-based access control, tenant isolation, audit logging, and a documented
incident-response process. See our Information Security Policy.
6. Data retention
Keel retains personal information for as long as needed to provide the service, and
thereafter as required for legal, regulatory (including financial-record retention),
tax, and audit purposes. Data processed on a tenant's behalf is retained per the tenant's
configuration and applicable law; see the Data Retention Policy.
7. Your rights and choices
Depending on your jurisdiction, you may have rights to access, correct, port, or delete
your personal information, and to object to or restrict certain processing. Because Keel
often acts as a processor for investor data, requests concerning a tenant's investor
data are directed to and fulfilled through that tenant (Keel assists the tenant as its
processor). For data where Keel is the controller (account, billing, website), contact us
using the details below. Keel provides a data-subject-request mechanism to support these
rights.
8. International data transfers
Where personal information is transferred across borders, Keel relies on appropriate
safeguards (such as Standard Contractual Clauses) as required by applicable data-protection
law. Keel's data-region and transfer posture is maintained with its tenants and counsel.
9. Children
The platform is intended for use by investment professionals and investors and is not
directed to children. Keel does not knowingly collect personal information from children.
10. Changes to this Policy
Keel may update this Policy from time to time. Material changes will be reflected here with
an updated date and, where appropriate, additional notice.
11. Contact
Questions about this Policy or Keel's data practices can be sent to privacy@keelmanager.com.
Investors with questions about a specific firm's handling of their data should contact that
firm directly.