Privacy Policy

Effective Date: January 1, 2026

This Privacy Policy ("Policy") describes how Keel Merchant Bank and its affiliates ("Keel," "we," "us," or "our") collect, use, and disclose information from and about you when you visit our website, https://www.keelmb.com/ (the "Site"), or use our services.

We respect and value your privacy. This Policy applies to our collection of personal information, which is information that can be used to identify you. This Policy applies to our website visitors, current and potential clients, and other business partners. If you are an employee, please refer to our internal personnel privacy policy.

We may collect the following types of personal information:

• Identity and Contact Data: your name, email address, phone number, mailing address, and other similar identifiers.

• Professional Information: your job title, company name, industry, and other information related to your professional background.

• Financial and Transactional Data: information about services you have engaged us for and information you provide to us in the course of our engagement.

• Technical Data: your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.

• Usage Data: information about how you use our Site and services.

We use different methods to collect data from and about you, including through:

• Direct Interactions: you may give us your Identity, Contact, and Professional Information by filling in forms on our Site, by corresponding with us by mail, phone, or email, or during the course of our business engagements.

• Automated Technologies or Interactions: as you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions, and patterns, using cookies and similar technologies.

• Third Parties or Publicly Available Sources: we may receive personal data about you from third parties and public sources, such as analytics providers and publicly available records.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To provide you with our services and to fulfill our obligations to you.

• To communicate with you, including to respond to your inquiries and to send you information about our services.

• To improve our Site and services.

• To comply with our legal and regulatory obligations.

• For our legitimate business interests, such as business analysis and fraud prevention.

We do not sell your personal information. We may share your personal information with the following parties for the purposes described in this Policy:

• Affiliates: we may share information among the entities of Keel Merchant Bank where appropriate to respond to your inquiry or provide a service.

• Service Providers: third-party service providers that perform services on our behalf, such as website hosting, data analysis, and communications.

• Professional Advisors: our professional advisors, such as lawyers, bankers, auditors, and insurers.

• Legal and Regulatory Authorities: legal or regulatory authorities if required by law or in response to a valid request.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We limit access to your personal data to those who have a business need to know.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Depending on your jurisdiction, you may have certain rights regarding your personal information, such as the right to access, correct, or delete your personal data. To exercise your rights, please contact us using the information below.

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Policy on this page. You are advised to review this Policy periodically.

If you have any questions about this Privacy Policy, please contact us:

Keel Merchant Bank, 106 W 56th St, 7th floor, New York, NY 10019, USA.