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Introduction

We are committed to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Keel Inc. collects. It also explains why we collect the information and how we use it.

Privacy is important to Keel. If you have any questions or if you believe that Keel has not adhered to this privacy policy, please send us a note at [email protected]

Summary

Information that we collect from you:

• We collect device-related information, server log information, and other types of anonymous information when you visit Keel and when you become a customer of Keel.

• Additionally, we collect personal information and financial information when you register and use your Keel account.

Why we collect your personal information

• We use your personal information to maintain your account, provide customer service, and enhance your customer experience.

• We use aggregated personal information and non-personal information to improve Keel and monitor and protect the security of our service.

Who we share your personal information with

• We do not sell, rent, or trade your personal information with any third parties except as provided in this privacy policy, with your consent, or as required by law.

Your choices as a consumer

• In order to operate Keel and provide managed financial services and retirement plan services, we require certain personal information.

• If you are not comfortable providing personal information to Keel, then our service won’t be useful to you and you will not be able to open an account with us.

How You Accept This Policy

By using and continuing to use the Keel websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms of Service take precedence over any conflicting privacy policy provision.

Information We Collect And Why

In order to provide a high quality service, Keel collects various types of information when you visit the website or sign-up as a customer.

As a Visitor

We collect various types of anonymous information about visitors to Keel, such as device-related information (browser type, IP address) and server log information (date and time of day of your visit). We also collect information that you input into our website. We use this information to better understand our visitors and our business, to provide the services or information you request, and to enhance the Keel service.

As an Individual

When you choose to create an account with Keel, we will also collect certain personal information, including your full legal name, email address, location, and date of birth. You may choose not to provide this information, but you cannot become a Keel customer without providing it.

Beyond the registration process, we may collect various other types of personal information if you use the site. We collect your email address as part of our customer referral service. Further, we may collect personal information if you contact us or otherwise give it to us (e.g., in an email).

Cookies & Pixels

Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.

We use these technologies in order to customize Keel and improve your experience with the site. Cookies store anonymous information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Keel and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites in order to better customize our marketing and advertising campaigns.

Cookies, pixels, and similar technologies are not required for site functionality.

Analytics Services

We use analytics tools such as “Google Analytics” (collectively referred to as “Analytics Services”) to collect information about the usage of this site. These analytics services collect information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We only use the information we get from these Analytics Services to improve this site.

These Analytics Services only collect the IP address assigned to you on the date you visit this site, not your name or other identifying information. We do not combine the information collected through the use of these Analytics Services with personally identifiable information. The Analytics Services ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies.

How We Use Your Personal Information

Keel uses personally identifiable and other collected information in a manner that is consistent with this privacy policy. We use your personal information to enhance your customer experience, operate and maintain your account in accordance with US law, investigate and understand how Keel is used, monitor and protect the security and integrity of Keel, and better market and advertise Keel’s services.

As part of this process, we may from time to time aggregate some of your personal information in certain data analysis, reports, or other interpretations of investment trends for both internal and external purposes. When aggregating personal information, we make sure that the information is not identifiable to any particular customer.

Additionally, we may use your personal information to contact you regarding our own services or resources that we think may be of interest to you. If you no longer wish to receive such marketing communications from Keel, please click the “unsubscribe” link that can be found at the bottom of each such email message. Please note that if you hold an account with Keel, you cannot opt-out of certain communications related to the administration of your account, including communications related to billing, statement delivery or certain regulatory matters.

When We Share Your Information

We do not sell, rent, or trade your personal information with any third parties without your consent or as required by law.

In order to provide financial services, we may share your personal information with third parties, such as consumer identification verification services and public accounting firms, for the purpose of serving you as a customer. We have entered into agreements that require that these third parties keep this information confidential.

If you conduct business with us through Keel for Advisors, we may exchange information we collect with your investment professional or with others they may authorize.

We also may share information, including but not limited to account positions, contributions, distributions, and cash flows, with a third-party financial institution that serves as a directed trustee to plans serviced by Keel for Business and its affiliates.

We also may disclose some of the personal information we collect to service providers, companies that perform marketing and analytics services on our behalf, or to other financial institutions.

We may disclose personal information in response to service of legal process, such as a court order, summons, subpoenas, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, frontrunning or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Service or customer agreements.

Information about our users, including personal information, may be disclosed or transferred to entities now or in the future affiliated with Keel or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any entity so receiving it.

Last, we may disclose personal information in specific other cases with your consent.

Children

Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Keel and/or provided us with personally identifiable information, please contact us at [email protected] Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.

How You Can Access Or Change Your Personal Information That We Have Collected

Once you have registered with Keel, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at [email protected] Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three years.

Protection Of Personal Information

Keel works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access, and we require third parties who perform services for Keel to agree to keep your information confidential. Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain a Keel account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

How We Respond To Do Not Track Signals

Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Customers using certain modern browsers have the ability to activate a “Do Not Track” signal. Keel does not currently respond to the “Do Not Track” signal.

Changes To The Policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app. Please check the effective date below to determine if there have been any changes since you have last reviewed the Keel privacy policy.

Your Rights As A California Resident

Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at [email protected] Your request should specify your full name and the email address you used when submitting personal information to us.

Your Rights As A Vermont Resident

We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into our Customer Agreement, please contact us at [email protected] Please note, however, that we will not be able to provide you with services through Keel without the ability to share this financial information.

International Visitors

This Service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

Questions

If you have any questions on the privacy policy, please contact us at:

Keel Inc.

695 Atlantic Ave, 9th Floor

Boston, MA 02111

[email protected]