Keel Privacy Policy

Last updated: 10/20/2026

About this policy

Keel by Surface Agency ("Keel") is an agency-operated platform for paid-media reporting, campaign creation, and optimization. Hand and Lever LLC, doing business as Surface Agency ("Surface", "we", "us"), operates it for Surface's clients.

This policy explains what information Keel gets from the advertising platforms we work in for you - Meta (Facebook and Instagram ads), Google Ads, The Trade Desk and Apple Ads - what we do with it, who else handles it, how long we keep it, and how to ask us to delete it. It also covers business figures you share with us for analysis, and information about people who contact us about Keel or whom we let sign in to Keel to view reports.

In this policy, "Keel" covers the Keel app that Surface staff use and the systems that collect your advertising data into Surface's Google Cloud for your reporting: our original scheduled data pulls and our newer data connectors.

Every client has a written agreement with Surface, which may set stricter rules, such as a shorter retention period. Where it does, we follow your agreement. Each platform's own privacy policy covers how that platform handles information.

How Keel works

Keel is an internal Surface tool. Surface staff run it only for clients that have a written agreement with Surface, and only Surface staff can change your advertising through it. You do not install Keel, and you do not sign in to it with your advertising platform accounts.

You give Surface access through each platform's own tools, for the accounts our work covers:

  • Meta: an administrator of your Meta business portfolio adds Surface's business portfolio as a partner in Meta Business Suite and shares the ad accounts - and, for campaign work, the Facebook Pages and Instagram accounts - that our work covers.
  • Google Ads: an administrator of your Google Ads account accepts a link to Surface's Google Ads manager account.
  • The Trade Desk: your Trade Desk administrator or account team issues Surface an API login. The login belongs to your business.
  • Apple Ads: an administrator of your Apple Ads account gives a Surface user API access to the accounts our work covers.

Keel then reaches those accounts through that access. You can remove it at any time using the same tools.

Keel makes campaign changes only through Surface's own approval steps, and only if you have engaged Surface to create or change campaigns on Meta or Google Ads. Keel does not change campaigns in The Trade Desk or Apple Ads. The access our data pulls use to collect your Meta reporting data can only read advertising data.

What Keel gets from advertising platforms

For the accounts you share with us, Keel receives:

  • Account details: each account's name, time zone, currency and status.
  • Campaign setup: your campaigns, ad sets or ad groups, and ads - their names, IDs, statuses, budgets, schedules, bidding and targeting settings, such as locations - and the names of the audiences they use.
  • Ad content: the creative behind each ad, such as its text, images, links and tracking parameters, and, on Meta, the Facebook Page and Instagram account the ad runs from.
  • Results: daily figures such as spend, impressions, reach, frequency, clicks, and the conversions or actions each platform reports, with their values and the attribution settings the platform used. This includes measurement totals some platforms provide, such as counts of store visits. For some Google Ads campaigns, Keel also gets figures such as impression share and where the ads ran.

What Keel does not get:

  • The platforms' results are totals. They do not tell us who saw or clicked an ad, and Keel does not receive the people in an audience or customer list.
  • Keel does not ask any platform for information about individual people, such as their profiles, posts, comments or messages.

Ad content can include information about people - for example, a person shown in an ad image or named in its text. We handle it as part of your ad content.

If you have engaged Surface for campaign work, Keel also sends information to Meta and Google Ads: the ads, budget changes and settings that Surface has approved for your accounts.

Other information we handle

  • Business figures you share with us. For analysis and budget pacing, you may give us, or let us read, figures from your own business, such as store-level visit totals or summary review scores. Keel uses totals like these, not records about individual customers.
  • People who contact us. When you email us about Keel, privacy, security or deletion, we keep your name, work email, business, role and what you tell us, so we can answer and keep a record of the request.
  • People who sign in to Keel. Surface staff sign in with their Google account. We may also give some of your staff read-only access to view aggregate performance reports for your own business only, using their Google account. Keel records each person's email address, their role in Keel, and the changes and approvals they make in Keel (an activity log). Keel uses two cookies to remember which client or advertiser you were viewing. Google's sign-in service sets its own cookies to keep you signed in. Keel does not use advertising or analytics cookies. Some Keel pages load map images directly from a map provider, which receives your browser's network address.
  • Business records. Which accounts you shared with us, who approved the access, and the requests you make.

How we use it

We use this information only to:

  1. report on your advertising for you, including dashboards, analysis and budget pacing;
  2. create and change campaigns, if you have engaged us to, through Surface's approval steps;
  3. run, secure and troubleshoot Keel, and check its numbers against each platform's;
  4. answer your requests and keep records of them; and
  5. meet our legal obligations and the platforms' terms.

We handle your data on your behalf and under our agreement with you. We do not:

  • sell or license it;
  • use one client's data for another client's work;
  • use it to build profiles of people or to monitor people;
  • use it to decide anyone's eligibility for housing, employment, credit, insurance, education or similar benefits; or
  • use it for Surface's own advertising.

Who we share it with

  • You, and others you ask us in writing to share it with.
  • The advertising platforms, when Keel creates or changes campaigns for you, and when a platform's terms require it.
  • Our service providers, who help us run Keel. They may use the data only to provide their service to us, under written agreements. They are:
    • Google Cloud: hosting, data storage and security logs;
    • Google Workspace: reports in Google Sheets, sign-in and email;
    • Slack: alerts and notices to our team;
    • GitHub: our software, and scheduled jobs that collect and report your data;
    • Anthropic and OpenAI: AI assistants that help our staff build and run Keel; and
    • CARTO: map images on some Keel pages, which receive your browser's network address.
  • Others when the law requires it, such as under a valid court order.

We do not sell your data.

Where we keep it

Surface keeps Keel's data mainly with Google Cloud in the United States. Some of the service providers above may keep copies in their own locations, and Surface staff computers may hold working copies, such as backups and files used for analysis. Within Surface, only staff we authorize, and the systems that run Keel, can see your data. People at your business we give report access can see reports for your business.

How long we keep it

  • Your reporting data: reports, campaign work, the data we build them from, and the data our original data pulls collect: While you are our client, plus 30 days
  • Raw data in our newer data connectors: copies of data exactly as a platform sent it: 90 days, with one exception below
  • Logs of our data pulls, data connectors and cloud setup: About 13 months (400 days)
  • The Keel app's own logs, including its activity log: No set period yet
  • Backups of the Keel app's database: Up to about 35 days

One exception today: while we prepare our newer Google Ads connector, it keeps Google Ads performance data, as Google sent it, for 365 days, so that we can rebuild your report history without pulling it from Google again.

We delete our records of each data pull and connector run with the rest of your data. Our data connectors' run records hold only internal codes, checksums and counts.

When our work for you ends, we delete your data within 30 days, without waiting for you to ask. Logs and backups are handled as this section describes.

The Keel app's own logs do not yet expire on a schedule. Backups of the Keel app's database expire within about 35 days. Backups cannot be erased one client at a time. We do not use them for normal work, and if we ever restore one, we delete your data from it again before anyone uses it.

Your agreement with Surface may set a shorter period, and a verified deletion request can end these periods early. If we must keep something longer - because the law or a contract requires it, or for a security, backup or audit reason - we record what it is, why, who is responsible, and when we will delete or review it. After we delete data, our cloud provider finishes erasing it from its own systems on its published schedule.

How we protect it

  • Access keys and API logins for the advertising platforms are kept in restricted storage that only authorized staff can access.
  • Keel changes campaigns only through Surface's approval steps.
  • Data we keep with our cloud provider is encrypted where it is stored, and data travels between systems over encrypted connections.

No system is perfectly secure. If we learn of a security incident affecting your data, we will tell you without undue delay, and we will report it to the affected platforms as their terms require.

We do not ask for the password or login code of anyone's personal advertising account. Where a platform needs an API login that your business issues to us, such as on The Trade Desk, we keep it in restricted storage, use it only for your work, and stop using it when your access ends.

Your choices

  • Remove access at any time in each platform's own tools. Keel then stops getting new data from those accounts. Please tell us too, so we can stop scheduled work and clean up.
  • Ask us for your reporting. You can ask us for the spend and campaign results we hold for your ad accounts, by emailing keel-support@surfaceagency.co or your Surface team.
  • Ask us what Keel holds about your business, or ask us to correct our records, by emailing privacy@surfaceagency.co.
  • Ask us to delete your data, by following the data deletion instructions.
  • If you are an individual, not a client, and think Keel holds information about you - for example, because you appear in a client's ad - email us. We usually hold this information for a client, so we may pass your request to that client and help them answer it.

Privacy rights where you live. Depending on where you live, you may have the right to ask what personal information we hold about you, to get a copy, to correct it, to delete it, or to object to how we use it. Email privacy@surfaceagency.co. We check who you are before we act on a request, and we will not treat you differently for using these rights. Where we hold the information for a client, we may pass your request to that client and help them answer it.

Children

Keel is a business tool. It is not meant for children, and we do not knowingly collect information about children.

Changes to this policy

When we change this policy, we post the new version here with a new date. Before a material change takes effect - such as a new use of your data, a new service provider, or keeping data longer - we email the main contact at each client.

Contact us

Each address reaches a monitored team mailbox, not one person's inbox. See security and support contacts.