Data Processing Agreement (DPA)

1. Relationship

The Subscriber (Agent/Brokerage) is the Data Controller. Jubilee is the Data Processor.

2. Scope of Processing

Jubilee shall process personal data only to provide mortgage renewal recommendations and platform maintenance.

3. Data Security

Jubilee implements technical and organizational measures to protect data, including:

  • Encryption: AES-256 at rest and TLS 1.2+ in transit.
  • Anonymization: Use of de-identified data for internal algorithmic training.

4. Sub-processors

Jubilee may use third-party sub-processors (e.g., AWS for hosting). A list is available to the Controller upon request.

5. Data Breach

In the event of a confirmed data breach, Jubilee will notify the Controller within 24-48 hours.

6. Audit Rights

Jubilee shall provide the Controller with necessary information to demonstrate compliance with privacy obligations.

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