Privacy

Privacy Policy

How Keel Technologies, Inc. collects, uses, shares, and protects information when you use our benefits enrollment platform and related services.

GDPR · CCPA · State Privacy Laws Consumer health data · WA MHMD · NV SB 370
Effective:September 7, 2026
Last updated:September 7, 2026
Version:v2026-09-07
Questions:[email protected]

1. About this policy and who we are

Keel Technologies, Inc. ("Keel," "we," "us," or "our") provides a broker-branded benefits platform. Brokers and employers use Keel to run open enrollment; the employees they sponsor use Keel to compare plans, model costs, ask questions, and submit their elections. This Privacy Policy describes how we handle information when you visit our website at keelbenefits.com (the "Site"), when you use the Keel application at app.keelbenefits.com or at a broker- or employer-branded subdomain of keelbenefits.com (the "Platform"), and when you otherwise interact with Keel.

Keel is based in the United States and our infrastructure is hosted in the United States. References to "you" in this policy include site visitors, broker users, employer administrators, and plan participants — the employees and dependents whose information we process in connection with the Platform.

For most of what we do with plan participant information, we act on the instructions of our customer — the broker or employer that sponsors the benefits program. That customer decides what data reaches us and why. Where you have a question we cannot answer without their direction, we will route it to them.

2. Information we collect

2.1 Information you give us directly

  • Account and contact information: name, work email address, phone number, employer or brokerage name, and job title.
  • Sign-in credentials: depending on how you sign in, a password, a passkey registered to your device, an authenticator-app secret, or a one-time code we send to your email address or phone.
  • Billing contact information: the billing contact and address we need to invoice a customer organization. Keel does not take card payments and does not process payments through the Platform.
  • Sales and support communications: the contents of messages you send us, meetings you book with us, and any files you choose to share.
  • Survey and feedback information: answers to optional surveys and feedback you submit through the Platform.

2.2 Information we receive about plan participants

When a broker or employer engages Keel, they direct us to receive information about the employees and dependents they sponsor. This usually arrives through a connection to their HR or payroll system, or by direct upload. It may include:

  • Identifiers: legal name, date of birth, home address, personal email address, phone number, employee identifier, and — because benefits administration systems and carriers match people on it — Social Security number.
  • Employment information: hire date, employment status, work location, job classification, occupational class, salary, and pay frequency.
  • Personal characteristics your employer's HR system holds and passes to us, such as gender, ethnicity, marital status, and student or disability status.
  • Household information: dependent names, dates of birth, relationships, and, where a carrier requires it, dependent identifiers.
  • Eligibility and election information: current and historical benefit elections, coverage tiers, contribution and deduction amounts, and effective dates.
  • Your answers to the benefits questionnaire and your conversations with Amanda. Some of this is consumer health data. Section 3 describes it separately.

2.3 Information from connected systems

  • HR and payroll systems connected through our HR-connectivity provider. These send us employee, dependent, and compensation records, and — where your employer asks us to — receive benefit deduction amounts back from us after enrollment closes.
  • Plan documents that brokers and employers upload. These are carrier product documents about plans, not records about people.

Keel does not connect to insurance carriers, and we do not receive information from them.

2.4 Information we collect automatically

  • Device and connection data: IP address, browser type and version, operating system, device identifier, language preference, and referring URL.
  • Usage data: pages and screens viewed, features used, links clicked, time spent, and error logs.
  • Cookies: we use a small number of strictly necessary cookies to operate the Platform, plus measured analytics cookies to understand usage. We do not use advertising cookies. See Section 11.5.

3. Consumer health data

Keel does not receive claims files, explanations of benefits, prescription records, or diagnoses. We do not accept them, and our customer agreements forbid sending them to us. But choosing a health plan means telling us something about your health situation, and some of what you tell us is consumer health data under Washington's My Health My Data Act, Nevada's SB 370, and similar state laws. This section is our account of that data. It applies in addition to the rest of this policy, and it controls where the two conflict.

3.1 What we treat as consumer health data

  • Your answers to the benefits questionnaire. These are the questions Keel asks to size your coverage — for example, whether you have other health coverage, whether you or a spouse are enrolled in a health flexible spending account elsewhere, whether you have used tobacco in the past twelve months, whether someone else claims you as a tax dependent, your household income range, how much of an unexpected bill you could absorb, and how you would want coverage to behave in a low-need year.
  • What you tell Amanda. Anything about your health, your family's health, expected care, or expected costs that you volunteer in a chat, a text message, an email, a voice call, or a video session — for example, "we're expecting a baby in September," "I need orthodontia covered," or "I take a specialty drug." Amanda does not ask you for a diagnosis, and you never have to give one, but what you say is stored in the conversation transcript.
  • The structured summary Amanda keeps about you — a short digest of your open questions, your stated preferences, and any life events you mentioned, so you don't have to repeat yourself when you switch from chat to a call.

3.2 Where it comes from

All of it comes directly from you, in the Platform. We do not buy consumer health data, we do not infer it from third-party sources, and we do not receive it from carriers, pharmacies, or providers.

3.3 What we use it for

We use consumer health data for one purpose: to produce benefits guidance for you — plan comparisons, cost estimates, eligibility results, a plan recommendation, and answers to the questions you ask. That is the whole list. Specifically:

  • We do not sell consumer health data. We have never sold it and we will not sell it. Under Washington law, selling it would require your signed, specific authorization; we do not seek one.
  • We do not use it for advertising, and we do not share it for cross-context behavioral advertising.
  • We do not use it to train general-purpose AI models, and our AI provider is contractually barred from doing so with what we send.
  • We do not use it to set your premium, to underwrite anything, or to make any decision about your employment. Keel does not underwrite, and your answers do not go to your employer's HR file.
  • We do not use geofencing around health facilities. Keel operates no such technology.

3.4 Who can see it

  • You. Your answers and your conversation history are visible to you in the Platform.
  • Your broker and the employer administrators who run your benefits program. They can see your questionnaire answers and the structured summary described above in the Platform's employee view, because they are the people who support you through enrollment and correct your enrollment when something is wrong.
  • Our subprocessors, by category in Section 7, strictly to run the features you are using: our cloud infrastructure, the model provider behind Amanda, and our speech, voice, video and messaging providers. Each is bound by contract to process the data only to provide its service to us, and we name them on request.
  • No one else. We do not share consumer health data with carriers, data brokers, advertisers, or analytics vendors. Keel has no corporate affiliates that receive it.

3.5 Your consent, and how to withdraw it

Where the law requires your consent before we collect consumer health data, we ask for it in the Platform — before the questionnaire or your first conversation with Amanda begins, and separately from any other agreement you are asked to accept.

Not every question is optional:

  • A few questions are required to work out what you are eligible for: whether you have other health coverage, whether you or a spouse have a health flexible spending account at another employer, whether someone else claims you as a tax dependent, and whether you have used tobacco. Tax rules and plan rules turn on these four answers, and our eligibility engine will not produce a result without them. If you would rather not answer them here, we cannot show you an eligibility result, and your broker or employer administrator will need to enroll you another way.
  • The rest are optional. The questions about your household income range, how much of an unexpected bill you could absorb, and how you would want coverage to behave in a low-need year exist only to sharpen your recommendation. Skip them and you can still compare plans and still enroll — the recommendation is less tailored.
  • Talking to Amanda is entirely optional. You can compare plans and complete your enrollment without ever starting a conversation.

You may withdraw your consent at any time, and you may ask us to delete your consumer health data. Withdrawal is prospective: it stops further collection and use. Deletion removes your questionnaire answers, your conversation transcripts, and the summary derived from them, and we will pass the deletion request on to the subprocessors described in Section 3.4 that hold any of it. If you withdraw or delete, Amanda loses the context behind any guidance she has already given, so we may no longer be able to show you a personalized recommendation — your elections and your coverage are unaffected.

To withdraw consent, request deletion, or ask what consumer health data we hold about you, email [email protected]. We will confirm your identity using information we already hold, and we will respond within the timeframe the applicable law requires. We will not discriminate against you for exercising any of these rights.

4. How we use information

  • To run the Platform. Enrollment, plan comparison, cost modeling, recommendations, eligibility, question answering, and generating the election and export files a broker submits to a benefits administration system.
  • To personalize guidance. To tailor plan comparisons and recommendations to the individual plan participant.
  • To communicate. Service notices, enrollment reminders, security alerts, billing notices, and — where you have opted in — product updates.
  • To support customers. To answer support requests and troubleshoot problems.
  • To protect Keel, our customers, and the public. To detect and prevent fraud, abuse, unauthorized access, and other security or integrity issues.
  • To improve the Platform. To debug, to measure performance, and to build new features. Where we can do that with aggregated or de-identified data, we do.
  • To comply with law. To meet legal obligations, respond to lawful requests, and enforce our agreements.

We do not sell personal information, we do not use plan participant information for advertising, and we do not share it for cross-context behavioral advertising.

5. How we use AI (Amanda)

Amanda is Keel’s AI adviser. She talks with plan participants over web chat, SMS, email, voice, and video.

  • We do not use your data to train AI models. Where we evaluate our own models we use de-identified or synthetic data, unless a customer has expressly authorized otherwise.
  • We keep the text of a conversation, not the audio, and video sessions are not recorded.
  • Amanda’s recommendations are decision support. They are based on the data your organization shares with us and on what you tell her, they can be wrong, and they do not replace the judgment of your broker or a licensed professional. You can always elect a plan other than the one she recommends.

6. How we share information

6.1 With your broker, your employer, and the systems they direct us to

Keel captures elections; it does not transmit them to carriers. At the close of enrollment, Keel produces a submission report and per-carrier export files. Your broker and an employer administrator review and approve them, and the broker uploads them into the employer's benefits administration system — most often Employee Navigator — or a carrier's own portal. That system, not Keel, transmits enrollment to the carriers and drives payroll deductions.

Keel has no direct connection to any insurance carrier. We do not send enrollment, eligibility, or premium files to carriers, and we do not submit evidence-of-insurability applications on your behalf.

Where your employer asks us to, we write benefit deduction amounts back to their payroll system through that provider.

6.2 With our subprocessors

We engage a small number of vendors to operate the Platform on our behalf. They are bound by contracts requiring them to protect information consistent with this policy and to use it only to provide their service to us. Their categories are in Section 7, and we name them on request.

6.3 For legal reasons

We may disclose information if we believe in good faith that doing so is necessary to comply with applicable law, regulation, legal process, or a lawful governmental request; to enforce our agreements; or to detect, prevent, or address fraud, security, or technical issues. Where law permits, we will give a customer notice and an opportunity to seek a protective order before responding to compulsory legal process directed at that customer's data.

6.4 In a business transaction

If Keel is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, information may be transferred as part of that transaction. Any acquirer remains bound by the commitments in this policy — including those in Section 3 — for information collected before the transfer, and we will use commercially reasonable efforts to notify customers of any material change in how their information is handled.

6.5 With your consent

We will share information for any other purpose we disclose to you at the time we collect it, or with your consent.

7. Subprocessors

We engage a small number of vendors to operate the Platform on our behalf: for infrastructure, for artificial intelligence, for communications, and for connectivity to our customers’ HR and payroll systems. All of them process information in the United States. Each is bound by contract to protect it consistent with this policy and to use it only to provide its service to us.

We provide the current list, naming each vendor, to customers and prospective customers on request at [email protected], and we give customers advance notice of a new subprocessor as our agreements require.

8. Data retention

We keep information for as long as it is needed to provide the Platform to the customer whose benefits program it belongs to, and afterwards only for as long as that customer’s agreement and applicable law require. Conversation transcripts are kept for the conversation and the summary drawn from it, and are then deleted. On termination we return or delete customer data as the customer’s agreement provides.

Where we hold information to resolve a dispute or meet a legal obligation, we keep it for that purpose and no other. To ask what we hold about you, contact [email protected].

9. HIPAA

Where we handle protected health information on behalf of an employer’s group health plan, we do so under a Business Associate Agreement, and that agreement governs the information rather than this policy. We sign a Business Associate Agreement where our customer or its plan requires one.

10. Security

Keel maintains a written information security program with administrative, technical, and physical safeguards appropriate to the sensitivity of the information it holds. That program includes encryption in transit and at rest, separation of each customer’s data from every other customer’s, controls on who may reach production data, and a documented incident response process. We will notify affected customers and individuals of a security incident as applicable law and our customer agreements require.

No security measure is perfect. If you believe your account, or any account at Keel, may have been compromised, contact [email protected] without delay.

11. Your privacy rights and choices

11.1 If you are an employee or dependent

Your employer or broker decides what information about you reaches Keel and why. You can exercise your privacy rights through them, and they may direct us to act. You can also come to us directly using the contact details in Section 15 — we will verify who you are and either handle the request or route it to your employer or broker and support them in answering it.

For your questionnaire answers and your conversations with Amanda, you can come straight to us: see Section 3.5.

11.2 California (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives you the right to ask us to (i) disclose the categories and specific pieces of personal information we hold about you, (ii) delete personal information we have collected, (iii) correct inaccurate personal information, and (iv) limit the use and disclosure of sensitive personal information. You have the right not to be discriminated against for exercising these rights.

We do not sell personal information, we do not share personal information for cross-context behavioral advertising, and we do not knowingly process the personal information of consumers under sixteen (16) years of age.

To exercise a right, email [email protected]. We will verify your request against information we already hold and may need to ask for more to confirm your identity. You may use an authorized agent, who must provide written authorization we can verify.

11.3 Washington, Nevada, and other US states

Washington residents (My Health My Data Act) and Nevada residents (SB 370) have specific rights in their consumer health data — to know what we collect and who receives it, to withdraw consent, and to have it deleted. Section 3 is written to serve those rights; Section 3.5 tells you how to use them. Washington's law also gives residents a private right of action.

Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states with comprehensive privacy laws have rights similar to those in Section 11.2. To exercise them, follow the process there.

11.4 European Economic Area, the United Kingdom, and Switzerland

If you are in the EEA, the UK, or Switzerland and the General Data Protection Regulation, UK GDPR, or the Swiss Federal Act on Data Protection applies to our processing, you have the right to access, rectify, erase, restrict, port, or object to our processing of your personal data, and you may lodge a complaint with your local supervisory authority. Where Keel acts as a processor for a customer, direct your request to that customer first. Where Keel acts as a controller, contact us at [email protected].

11.5 Cookie choices

Most browsers let you control cookies in their settings. If you block cookies, some Platform features may not work as expected. We honor Global Privacy Control (GPC) signals as a valid opt-out request where applicable law recognizes them. We do not respond to the older "Do Not Track" browser setting, for which no industry standard was established.

11.6 Marketing email choices

You can opt out of marketing email by following the unsubscribe instructions in any marketing message, or by contacting [email protected]. We will still send the transactional and service messages needed to operate the Platform and run your enrollment.

12. International data transfers

Keel is based in the United States and our infrastructure is hosted in the United States. If you access the Platform from outside the United States, your information will be transferred to, stored in, and processed in the United States. Where we transfer personal data from the EEA, the UK, or Switzerland to the United States, we rely on the European Commission's Standard Contractual Clauses, the UK Addendum, and the Swiss Addendum, as applicable, supported by the additional safeguards described in our security documentation (available on request).

13. Children

The Platform is not directed to children under sixteen (16), and we do not knowingly collect personal information directly from them. Information about a dependent child — a name, a date of birth, a Social Security number, a relationship — reaches us from the employer, the broker, or a parent or guardian acting through the enrollment experience, so the child can be enrolled in coverage.

Dependent information is provided under the authority of the enrolling parent or guardian, is used solely for enrollment, eligibility, and the administration of the coverage it was provided for, is protected with the same field-level encryption as adult data, and is never used to train AI models. A parent or guardian can review or correct a dependent’s information at any time through the enrollment experience, through their employer, or by contacting us at the address in Section 15.

14. Changes to this policy

We may update this policy from time to time. Each version carries a version string (this one is v2026-09-07) and a "Last updated" date. If we make a material change — in particular, any change to Section 3 — we will post the updated policy at this URL, update the version, and notify customers in writing or through the Platform. Where the law requires your fresh consent for a new use of consumer health data, we will ask for it before that use begins, not by quietly amending this page.

15. How to contact us

Questions about this policy, or about how we handle your information:

Keel Technologies, Inc.
[email protected]