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PRIVACY POLICY

 

Last Updated: August 17, 2026

Introduction

Keeper Solutions is a market-leading software development partner for innovative FinTech, CleanTech and MedTech firms. We specialize in the highly regulated FinTech space and have forged long-lasting partnerships with multiple enterprise-level companies and fast-scaling start-ups in this sector, both in the United States and in Europe. Learn more about us at http://keepersolutions.com/.

We are committed to protecting your personal information. The following describes how we collect, process, and store your personal information in accordance with applicable laws, including the ePrivacy Directive, the EU General Data Protection Regulation (GDPR) (Regulation 2016/679), and the Irish Data Protection Acts 1988 to 2018.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, send us an email, apply for a job, enter into any business transaction with us, or access our online platforms and products. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please exit our site and do not introduce any personal details.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted. Only subscribers to our “sign me up” newsletter will receive specific emailed notice of each such change or modification.

1. Responsibility Over Data Collected (Data Protection Roles)

Under GDPR and Irish Data Protection Law, the legal role of Keeper Solutions depends on the nature of your interaction and the type of data being processed:

1.1 Keeper Solutions as Data Controller

We act as the Data Controller for general website interactions, business relationships, marketing activities, recruitment data, and product account management. In this capacity, we determine the purposes and means of the processing. Specifically, this includes:

  • Website Visitors: Derivative data, cookies, and technical log files collected during your visit.
  • Recruitment Candidates: CVs, portfolios, and application tracking data submitted via our site or external databases.
  • Business Contacts and Clients: Contact details and invoicing data used to establish and manage our business contracts.
  • HubGate Account and Billing Data: For users of our HubGate platform, we act as the Controller for account registration details (e.g., email address, name, social login tokens) and billing/transaction metrics managed via Stripe.

1.2 Keeper Solutions as Data Processor

We act strictly as a Data Processor on behalf of your organisation (the Data Controller) for all Interaction Data processed within certain specialized products.

  • HubGate Interaction Data: This includes all user-submitted prompts, queries, uploaded files, and connected third-party knowledge bases (such as Google Drive). In this capacity, we process data solely in accordance with the documented instructions of the Customer organisation, as defined in our B2B Data Processing Agreement.

1.3 Interaction with Product-Specific Privacy Policies

Keeper Solutions provides some of its specialized offerings under separate product-specific terms. For instance, users accessing the HubGate platform are subject to the detailed HubGate.io Privacy Policy.

  • Order of Precedence: This general Privacy Policy provides an overarching framework for Keeper Solutions’ business operations. However, for users of specific platforms (such as HubGate), the product-specific Privacy Policy governs those platform operations and supersedes this general policy in the event of any direct conflict or inconsistency.

2. What Information We Collect and Why

2.1 Personal Data

Please note you are under no obligation to provide us with personal information of any kind, as you may opt to navigate our Sites for information purposes. Should you choose to engage with us, we may collect Personally Identifiable Information, such as:

  • Your name, email address, and other identification details voluntarily provided in connection with newsletter sign-up, general business queries, or the use of site communications (such as chat functions).
  • Professional email addresses and contact numbers of our Customer’s personnel, used solely for the performance of contracted services.
  • For users registering on the HubGate platform, we collect sign-up details (email address, name, login credentials) or social login authentication tokens (via Google Workspace or Microsoft Azure AD OAuth) to manage your account, verify eligibility (minimum age of 18), and control platform access.

2.2 Business Identity and Company Information

We collect business identity data when you enter into a business transaction with us to establish a contract, register your company in our invoicing system, and manage our business activities. All customer data and business information are treated as strictly confidential.

2.3 Derivative and Technical Data

This refers to information that our servers automatically collect when you access our Sites, allowing us to generate statistics regarding platform performance. This includes:

  • IP addresses, browser types, operating systems, access times, and pages viewed before and after accessing our site.
  • For HubGate users, we also maintain real-time metering logs via LangFuse to track query usage and calculate credit consumption to enforce our Fair Use Policy.

2.4 Cookies, Log Files, and Tracking

Cookies are pieces of data placed on your browser to facilitate future visits, customize experiences, and collect web history. We use cookies for authentication, security, performance, analytics, and research.

  • Third-Party Cookies: We utilize third-party analytics such as Google Analytics, GA4, and Hotjar to understand site traffic and usability. Video embeds from our official YouTube channel in privacy-enhanced mode may also set cookies.
  • Opt-out: You may regularly clean your cookie history or adjust your selections via the cookie consent banner displayed during your visit.
  • Web Beacons: We deploy web beacons for email tracking to unobtrusively verify that a user has accessed sent content.
  • Social Plugins: Initially, no personal data is passed to social media providers, such as LinkedIn, YouTube, or Facebook. Only when you click a plugin is data transferred to the respective social media platform.
  • Log Files: We gather and store information in log files, including IP, browser type, geographic location, and user activity logs, for security, statistical, and operational administration.

2.5 Recruitment and Applicant Tracking Data

Job applications submitted through our site are processed using an applicant tracking system called Breezy HR. Occasionally, we may use recruitment management specialists, in which case you will be informed about the transition of your CV. Upon successful recruitment, the applicant tracking data links automatically into our HR system, BambooHR.

3. What Information We Receive from Other Entities

We may receive information about you through social media interactions or public profiles:

  • We may link the data you provide to us with other publicly available information you have published on the Internet, such as LinkedIn profiles.
  • We may search various databases, both public and non-public, including your CV or resume, to identify potential candidates for job openings.
  • We may receive your personal data via third-party recommendations for specific job openings or business opportunities.

4. How We Use Your Information

Having accurate information about you permits us to provide a smooth, efficient, and customized experience. We may use information collected via our Site in various ways:

  • To create and manage business relationships through our CRM, and perform transactional business activities.
  • To provide site support, resolve disputes, troubleshoot problems, and increase operational efficiency.
  • To respond to customer service requests, manage job applications, or send marketing newsletters and satisfaction questionnaires.
  • To compile anonymous statistical data and analyze usage trends internally or with trusted third parties.
  • To assist law enforcement or provide evidence of compliance if legally required.

Legal Bases for Processing

We process your personal data under the following legal bases:

  1. Consent under GDPR Article 6(1)(a): For newsletters and non-essential cookies, which you can withdraw at any time.
  2. Performance of a Contract under GDPR Article 6(1)(b): For executing development agreements, managing accounts, or fulfilling recruitment applications.
  3. Legal Obligations under GDPR Article 6(1)(c): For compliance with financial, corporate record-keeping, and legal requirements.
  4. Legitimate Interests under GDPR Article 6(1)(f): For website improvement, performance optimization, and aggregate business analytics.

5. How Is Your Information Secured?

We work to protect the security of your personal information using robust technical and administrative safeguards.

  • Encryption and Standards: We use industry-standard software and encryption protocols. For specialized products like HubGate, all chat messages, prompts, and database entries are secured using application-layer AES-256-GCM encryption prior to storage, preventing plaintext exposure.
  • ISO 27001 Certification: Keeper Solutions maintains an active, certified ISO 27001 Information Security Management System across all of our development, device management, and operational environments to ensure continuous threat detection and risk control.
  • Identity Verification: We may ask you to verify your identity before disclosing personal information to you.
  • Good Practices: No security measure is entirely impenetrable, and we encourage users to follow secure online practices, such as managing credentials safely and reporting suspected data breaches to privacy@keepersolutions.com.

6. How Long Do We Keep Your Personal Information?

We retain personal data only for as long as necessary to satisfy the purposes for which it was collected, including legal, regulatory, tax, accounting, or reporting requirements.

  • Recruitment Data: We hold candidate data for up to 24 months, after which we will reach out for explicit consent to retain it longer.
  • Business Identity Data: Contacts, invoicing records, and transaction histories are maintained in line with legal and fiscal audit requirements.
  • HubGate Platform Data: Account registration, billing metadata, and technical usage metrics are retained for as long as your subscription is active, or as required for accounting purposes.
  • Platform Switching and Erasure: In line with our B2B switching policy, clients retain complete ownership of their conversational history. Upon a request to terminate your account or switch providers, we will permanently and securely erase all stored chat history, indexed knowledge files, and personal data from our active databases, subject only to mandatory legal retention.

7. Disclosure and Transfers of Data

7.1 Service Providers and Sub-Processors

We may pass your personal information to trusted third-party service providers who process work strictly on our behalf, such as recruitment agencies, payment processors like Stripe, hosting services, and customer support. These providers are contractually bound to process data based on our instructions, and are prohibited from sharing your data without authorization.

7.2 Third-Party AI Data Transmission — HubGate Carve-out

Keeper Solutions is dedicated to maintaining the absolute confidentiality of client and company data.

  • Commitment to Non-Disclosure: Keeper Solutions does not share any Customer Company or Business data with third parties within our core development, consulting, and operational services.
  • For the Avoidance of Doubt, HubGate Carve-out: This non-disclosure commitment applies strictly to our core development, consulting, and operational activities. Specialized products like HubGate operate on a separate, customer-directed workflow in which user-submitted Interaction Data, including prompts, queries, and files, is intentionally transmitted to third-party large language model providers such as OpenAI, Anthropic, Google, and Perplexity, selected by the customer. This transmission is an inherent and essential feature of the HubGate service.
  • Personally Identifiable Information Filtering: Prior to transmitting any data to external large language model endpoints, the Platform analyzes prompts and files using an automated governance layer designed to detect, identify, and mask personally identifiable information to protect sensitive data.
  • Training Prohibition: All third-party AI model providers utilized by HubGate are bound by strict agreements prohibiting them from using your prompt content, queries, or knowledge base files to train their proprietary AI models.

7.3 International Data Transfers

While our primary operational and processing facilities are situated within the EEA, our business activities may require the transfer of personal data to countries outside the EU/EEA, such as the United States.

  • Systemic AI Transfers: For products like HubGate, data routing to US-based AI model providers represents a routine and systemic part of the service delivery.
  • Contractual Safeguards: Any such international transfers of data occur strictly under a lawful international data transfer mechanism, including approved Standard Contractual Clauses, to safeguard your rights and enforce equivalent data security.

8. Operational and Development Integrity (Subcontracting)

Keeper Solutions maintains absolute control over its delivery teams to guarantee software quality and IP security:

  • Internal Personnel Commitment: All our operational services are performed by Keeper Solutions personnel, and Keeper Solutions does not subcontract developments.
  • For the Avoidance of Doubt, Third-Party AI Integration: The statements that all operational services are performed by Keeper Solutions personnel, and that Keeper Solutions does not subcontract developments, refer specifically to our internal software engineering, support operations, consulting, and contracted managed-service activities.
  • Certain Keeper Solutions products, including HubGate, integrate with external third-party AI model providers as an inherent, intended, and customer-directed feature. The use of these third-party AI systems for inference does not constitute subcontracting or outsourcing of Keeper Solutions’ operational or development obligations. This external processing is performed strictly within the scope of the HubGate service and under appropriate contractual, technical, and data-protection safeguards.

9. Artificial Intelligence and Automated Processing

Keeper Solutions is committed to the responsible, ethical, and legal use of artificial intelligence in line with emerging regulations, including the principles of the EU AI Act. This section outlines how we use AI technologies and the safeguards we have in place to protect your data and ensure fairness.

9.1 Purpose of AI Processing

We may use AI and machine learning systems for legitimate business purposes, primarily to support our internal teams and enhance our services. These purposes include:

  • Productivity and Service Enhancement: Assisting our software engineering and business development teams in generating code, creating marketing content, and analysing business data to improve our service offerings.
  • Business Analytics: Processing aggregated and anonymised data to identify trends, understand user engagement, and inform product development strategies.
  • Decision Support: Providing insights to support our expert staff. Our AI systems do not engage in fully automated decision-making that has a legal or similarly significant effect on individuals.

9.2 Data Minimisation in AI Systems

We apply the principle of data minimisation to all AI processing activities:

  • We only process personal data that is strictly necessary for the specific, predefined purpose of the AI task.
  • Wherever feasible, we use anonymised or pseudonymised data for AI model analysis to eliminate or reduce privacy risks.
  • Our internal governance policies strictly prohibit the input of sensitive personal data, client confidential information, or proprietary trade secrets into public or third-party AI models.

9.3 Risk Mitigation and Human Oversight

We recognise the potential risks associated with AI, including bias and inaccuracy, and implement robust measures to mitigate them:

  • Human Oversight: We maintain a human-in-the-loop approach for any process where AI-generated insights inform significant decisions. AI serves as a supportive tool for our expert staff, not as a replacement for human judgment.
  • Bias and Fairness Reviews: Our AI systems and the data they use undergo regular review to identify, assess, and mitigate potential biases to ensure fairness and non-discriminatory outcomes.
  • Validation: All AI-generated content or analysis is reviewed and validated by a qualified team member before being used for any external or critical internal purpose.

9.4 Use of Third-Party AI Providers

To perform certain tasks, we may utilise AI services and models developed by trusted third-party providers, such as large language models from providers like OpenAI, Google, or Microsoft. Our use of these providers is governed by strict controls:

  • Due Diligence: All third-party AI providers are subject to a rigorous vetting process to ensure they meet our data protection, security, and ethical standards.
  • Contractual Safeguards:

10. Your Rights as a Data Subject

If you reside in the European region, you hold the following statutory rights under the GDPR and Irish Data Protection Law:

  • Right of Access: Request a copy of the personal data we hold about you.
  • Right to Rectification: Request correction of incomplete or inaccurate data.
  • Right to Erasure (To Be Forgotten): Request deletion of your data when there is no legitimate legal basis for its continued processing.
  • Right to Object: Object to our processing of your personal data on legitimate interest grounds or for direct marketing.
  • Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent (e.g., newsletters).
  • Right to Object to Automated Decision-Making: Object to automated processing, including profiling, and the right not to be subject to the legal effects of fully automated decisions.
  • Right to Data Portability (AI Export): Request the transfer of your data to you or a designated third party in a structured, commonly used, machine-readable format. In line with EU guidelines on AI data rights, this specifically includes the right of users on our AI-powered platforms (such as HubGate) to export full conversational histories, custom prompt libraries, and AI-generated outputs prior to account termination.

To exercise any of these rights, please contact our Information Security Manager. We will respond to all valid requests within thirty (30) days, free of charge.

11. Queries, Requests, and Complaints

11.1 Compliance Contact

Our Information Security Manager oversees all data protection compliance and Data Subject Access Requests (DSARs). For any questions, requests, or concerns, please contact our dedicated privacy inbox:

11.2 Regulatory Authorities

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a regulatory authority, particularly the Data Protection Commission in Ireland:

  • Data Protection Commission (DPC):
  • Office of the Information Commissioner (OIC):
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