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Legal

Privacy Policy

Effective Date: March 30, 2026 · Last Updated: March 30, 2026
Keel Financial, Inc. DBA Keel (“Keelcard,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, and protect information when you visit our website at keelcard.com (the “Site”) or interact with our services. This policy applies to all visitors, users, and prospective customers of the Site.

1. Information We Collect

1.1 Information You Provide to Us

We collect information you voluntarily provide when you use our Site, including when you:

  • Submit information through our waitlist or early access form, including your first and last name, email address, phone number, estimated credit score range, and property information (address, property type, estimated value, current mortgage details)
  • Contact us via email or other communication channels
  • Respond to surveys, promotions, or other requests for information

1.2 Information We Collect Automatically

When you visit the Site, we may automatically collect certain information about your device and usage, including:

  • IP address, browser type and version, operating system
  • Pages viewed, time spent on pages, referring URLs
  • Device identifiers and general location data (city/state level, not precise geolocation)

We collect this information using cookies, pixels, and similar tracking technologies. See Section 7 below for more detail.

1.3 Information We Do Not Currently Collect

At this stage, we do not collect Social Security numbers, full credit reports, financial account numbers, bank account credentials, income documentation, or government-issued identification through the Site. Our waitlist form collects only a self-reported estimated credit score range — we do not perform credit pulls (hard or soft) based on waitlist submissions.

When Keelcard launches as a credit product, we will collect additional information required by federal and state lending regulations, including information necessary to verify identity, assess creditworthiness, and comply with the Fair Credit Reporting Act (FCRA), Truth in Lending Act (TILA), and the Gramm-Leach-Bliley Act (GLBA). This Privacy Policy will be updated accordingly before any credit product is offered.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • Waitlist and communications: To add you to our early access waitlist, contact you about product availability, and provide personalized rate estimates when our product launches
  • Site operation and improvement: To operate, maintain, and improve the Site and our services
  • Analytics: To understand how visitors use the Site, analyze trends, and improve user experience
  • Legal compliance: To comply with applicable laws, regulations, and legal processes
  • Security: To detect, prevent, and address fraud, security issues, and technical problems

3. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We do not share your personal information with lenders, banks, or other financial service providers.

We may share your information in the following limited circumstances:

  • Service providers: We may share information with third-party vendors who perform services on our behalf, such as website hosting, email delivery, and analytics. These providers are contractually obligated to use your information only to provide services to us.
  • Legal requirements: We may disclose information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect our rights, the safety of others, or to investigate fraud.
  • Business transfers: If Keelcard is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a different privacy policy.

When Keelcard launches as a credit product, we may share information with credit bureaus, identity verification providers, bank partners, and other parties as required to originate and service your account. We will update this Privacy Policy and, where required by the Gramm-Leach-Bliley Act, provide you with a separate financial privacy notice before any such sharing occurs.

4. Your Rights Under California Law (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with the following rights:

  • Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the business purposes, and the categories of third parties with whom we share it.
  • Right to Delete: You may request deletion of personal information we have collected, subject to certain exceptions.
  • Right to Correct: You may request correction of inaccurate personal information.
  • Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information as defined under the CCPA/CPRA. If this changes, we will update this policy and provide a conspicuous opt-out mechanism.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your rights.

To exercise any of these rights, contact us at the information in Section 10 below. We will verify your identity and respond within 45 days.

Certain information collected in connection with a credit application may be exempt from CCPA/CPRA under the Gramm-Leach-Bliley Act (GLBA) exemption. This exemption applies only to information collected in a financial services context, not to general website browsing or waitlist data.

5. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by law. If you request deletion, we will delete or de-identify your information within 45 days of verifying your request, unless a legal exception applies.

6. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, use, alteration, and disclosure. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

7. Cookies and Tracking Technologies

The Site may use cookies and similar technologies to collect information about your browsing activity. You can control cookies through your browser settings.

  • Essential cookies: Necessary for the Site to function properly
  • Analytics cookies: Help us understand how visitors use the Site (e.g., Google Analytics)

We do not use advertising or retargeting cookies at this time.

8. Third-Party Links

The Site may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties.

9. Children's Privacy

The Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights under California law, contact us at:

Keel Financial, Inc. DBA Keel
Email: privacy@keelcard.com

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or applicable law. We will post the updated policy on this page with a revised “Last Updated” date. Material changes will be communicated via a prominent posting on the Site or email notification.

Legal

Terms of Service

Effective Date: March 30, 2026 · Last Updated: March 30, 2026
These Terms of Service (“Terms”) are a legal agreement between you (“you” or “your”) and Keel Financial, Inc. DBA Keel (“Keelcard,” “we,” “us,” or “our”). These Terms govern your access to and use of the Keelcard website at keelcard.com (the “Site”). By accessing or using the Site, you agree to be bound by these Terms. If you do not agree, do not use the Site.

1. Acceptance of Terms

By accessing the Site, you represent that you are at least 18 years of age and have the legal capacity to enter into these Terms. These Terms, together with our , constitute the entire agreement between you and Keelcard regarding your use of the Site.

2. Description of the Site

The Site is an informational website that provides general information about Keelcard's planned HELOC-backed credit card product and allows prospective customers to join a waitlist.

The Site does not constitute an offer to extend credit, a solicitation of a credit application, or a commitment to lend. Keelcard is not currently issuing credit cards, extending lines of credit, or originating HELOCs. All product terms displayed on the Site — including APR ranges, credit limits, fees, cash back rates, and eligibility criteria — are anticipated terms and are subject to change. Final terms will be determined based on applicable regulatory requirements, creditworthiness, and other factors at the time of application.

3. Not a Credit Application

Submitting information through the waitlist or early access form is not a credit application. No waitlist submission will:

  • Result in a hard or soft credit inquiry
  • Create an obligation on the part of Keelcard to extend credit
  • Guarantee approval, a specific rate, credit limit, or any product terms
  • Constitute a binding agreement of any kind

When Keelcard's credit product launches, a separate application process will be required, which will involve credit checks, income verification, property valuation, and compliance with all applicable federal and state lending regulations including the Truth in Lending Act (TILA), Equal Credit Opportunity Act (ECOA), and Fair Credit Reporting Act (FCRA).

4. Product Information, Rates, and Comparisons

The Site contains information about Keelcard's planned product features and comparisons with third-party products. You acknowledge and agree that:

  • Rates and terms are illustrative only. APR ranges, credit limits, cash back rates, fees, and other product terms shown on the Site are anticipated and have not been finalized. Actual rates and terms will depend on market conditions, regulatory requirements, your creditworthiness, property value, and other factors determined at the time of application.
  • Savings projections are hypothetical. Any savings calculations, interest comparisons, or cost examples shown on the Site are illustrative only and are not guarantees of actual savings.
  • Third-party information is from public sources. Competitor data shown in comparison tables is sourced from publicly available websites and marketing materials as of the date indicated. Terms may have changed. Contact each provider directly for current information.
  • Testimonials are illustrative. Member stories or testimonials displayed on the Site represent individual experiences and are not guarantees of results. Your experience may vary.
  • No endorsement. The inclusion of any third-party company in a comparison does not constitute an endorsement or affiliation.

5. No Financial, Legal, or Tax Advice

Nothing on the Site constitutes financial, legal, tax, or investment advice. The information is for general informational purposes only. A HELOC-backed credit card is a credit product secured by your home — before entering into any agreement secured by your home, you should consult with a qualified financial advisor, attorney, or housing counselor.

6. Home Equity Risk Disclosure

A HELOC-backed credit card is secured by a lien on your home. If you are unable to make required payments, you could lose your home through foreclosure. Before using home equity to secure a credit product, carefully consider your ability to repay and the risks involved. This disclosure will be provided in greater detail in the product's credit agreement and TILA disclosures at the time of application.

7. Intellectual Property

The Site and its contents are the property of Keel Financial, Inc. or its licensors and are protected by copyright, trademark, and other intellectual property laws. You may not reproduce, distribute, modify, or create derivative works without our prior written consent.

The name “Keelcard” and associated logos are trademarks of Keel Financial, Inc. Third-party names and logos are trademarks of their respective owners, used for informational comparison purposes only.

8. User Conduct

You agree not to:

  • Use the Site for any unlawful purpose
  • Submit false, misleading, or fraudulent information
  • Attempt to gain unauthorized access to the Site or related systems
  • Interfere with or disrupt the Site's operation
  • Use automated means to access the Site without prior written consent
  • Impersonate any person or entity

9. Disclaimers

THE SITE IS PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. We disclaim all warranties, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

We do not warrant that the Site will be uninterrupted, error-free, or secure, or that any information on the Site — including rates, terms, comparisons, and savings projections — is accurate, complete, or current.

10. Limitation of Liability

To the fullest extent permitted by law, Keel Financial, Inc. and its officers, directors, employees, agents, and affiliates shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to your use of the Site.

In no event shall our total liability exceed one hundred dollars ($100). Some jurisdictions do not allow certain limitations — in such cases, our liability is limited to the greatest extent permitted by law.

11. Indemnification

You agree to indemnify and hold harmless Keel Financial, Inc. and its officers, directors, employees, agents, and affiliates from any claims, liabilities, damages, losses, costs, and expenses arising out of your use of the Site or violation of these Terms.

12. Governing Law and Dispute Resolution

These Terms shall be governed by the laws of the State of California, without regard to conflict of law provisions. Disputes shall be resolved exclusively in the state or federal courts located in Los Angeles County, California.

13. Notice for California Residents

If you are a California resident, in accordance with Cal. Civ. Code §1789.3, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by contacting them in writing at 400 R Street, Sacramento, CA 95814, or by telephone at (800) 952-5210.

14. Changes to These Terms

We reserve the right to modify these Terms at any time. Updated Terms will be posted on this page with a revised “Last Updated” date. Continued use of the Site after changes constitutes acceptance.

15. Severability

If any provision is held invalid or unenforceable, the remaining provisions continue in full force and effect.

16. Contact Us

If you have questions about these Terms, contact us at:

Keel Financial, Inc. DBA Keel
Email: legal@keelcard.com

Legal

Licenses & Registrations

Last Updated: March 30, 2026
Keel Financial, Inc. DBA Keel (“Keelcard”) is committed to operating in full compliance with all applicable federal and state laws governing consumer lending, credit products, and financial services. Below is a summary of our regulatory licenses and registrations.

NMLS Registration

Pending

Registration with the Nationwide Multistate Licensing System (NMLS) is required for mortgage lending and HELOC origination. Our NMLS ID will be displayed here once obtained.

NMLS Consumer Access →

California DFPI — California Financing Law (CFL) License

Pending

A CFL license from the California Department of Financial Protection and Innovation (DFPI) is required to originate consumer loans, including HELOCs, in the State of California.

Visa Network Membership

Planned

Keelcard intends to issue cards on the Visa network, which requires either direct membership or a partnership with a Visa-issuing bank. Details on our issuing bank partnership will be disclosed here once finalized.

Additional State Licenses

Planned

Depending on geographic expansion, additional state mortgage lending or consumer finance licenses may be required. We will obtain all required licenses before offering products in any state.

Regulatory Disclosures

Upon product launch, the following regulatory disclosures will be provided to applicants as required by law:

  • Truth in Lending Act (TILA / Regulation Z) disclosures: Including APR, finance charges, payment terms, and total cost of credit
  • HELOC-specific disclosures: As required under Regulation Z §1026.40, including an initial disclosure statement, a program brochure (or equivalent), and periodic statements
  • Equal Credit Opportunity Act (ECOA) notices: Including adverse action notices where applicable
  • Fair Credit Reporting Act (FCRA) notices: Including credit report authorization and adverse action based on credit information
  • Gramm-Leach-Bliley Act (GLBA) privacy notice: A separate financial privacy notice will be provided to customers at account opening
  • Right of rescission: As applicable under TILA for credit secured by a principal dwelling

Contact

For questions about licensing or regulatory compliance, contact:

Keel Financial, Inc. DBA Keel
Email: compliance@keelcard.com

Legal

Accessibility Statement

Last Updated: March 30, 2026
Keel Financial, Inc. DBA Keel (“Keelcard”) is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone and strive to conform to the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA.

Our Commitment

We believe that all users — including those with visual, auditory, motor, or cognitive disabilities — should be able to access and use our website. We are actively working to ensure our Site meets or exceeds accessibility standards, including:

  • Providing text alternatives for non-text content
  • Ensuring sufficient color contrast between text and backgrounds
  • Making all functionality accessible via keyboard navigation
  • Providing clear and consistent navigation throughout the Site
  • Using semantic HTML markup and ARIA attributes where appropriate
  • Ensuring forms are properly labeled and accessible to screen readers
  • Avoiding content that flashes more than three times per second

Conformance Status

We aim to conform to WCAG 2.1 Level AA. We are incorporating accessibility best practices from the outset and will conduct formal accessibility testing before product launch. We recognize that some areas of the Site may not yet fully conform and are actively working to address gaps.

Third-Party Content

Our Site may include content or features provided by third parties. While we strive to ensure third-party content meets accessibility standards, we may not have full control over these components. We work with our vendors to prioritize accessibility in all integrations.

Feedback

We welcome feedback on the accessibility of the Keelcard website. If you encounter accessibility barriers or have suggestions for improvement, please contact us:

Email: accessibility@keelcard.com

We will make reasonable efforts to respond to accessibility feedback within 5 business days and to resolve identified issues in a timely manner.

Enforcement and Compliance

When Keelcard launches its credit product, we will comply with all applicable accessibility requirements under the Americans with Disabilities Act (ADA) and Section 508 of the Rehabilitation Act, as well as any applicable state accessibility laws.

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