Document DPA-01
Data Processing
How Latitude handles your documents — the agreements you upload, the playbook inferred from them, and the redlines produced. This is the document your legal team will actually read.
Effective 16 August 2026
1. Roles
You are the controller of your documents and your playbook. Latitude is a processor acting on documented instructions under an executed order form and data processing agreement.
Most of what you upload is somebody else’s paper, subject to a confidentiality obligation you owe a counterparty. We treat every document as confidential regardless of its source, because from our side it always is.
We have no independent right to use your documents. Every permitted use flows from your instructions.
2. Your playbook is yours
The playbook inferred from your agreements is your property. It is exportable in a portable form at any time, we claim no rights in it, and it never forms part of any product, dataset or benchmark offered to anyone else.
A vendor that owns your negotiating positions holds leverage over you in your own commercial relationships. That is a bad shape for this relationship and the agreement is written to prevent it.
3. Confidentiality and segregation
Documents and playbooks are segregated at the storage, processing and access layers, and are never shared or pooled between customers for any purpose, including product improvement.
Access is limited to personnel assigned to your account, on a least-privilege basis that is logged and reviewed. There is no standing access to customer documents.
- Your documents are never used to train or fine-tune models.
- Your playbook is never used to inform any other customer’s playbook.
- Any model provider in the processing path is bound to zero data retention and to no training on submitted data.
- Product telemetry excludes document content entirely.
4. Personal data
The personal data involved is ordinarily limited to business contact data: the names, roles and work contact details of your staff and of counterparty signatories appearing in the agreements themselves.
Processing relies on contract performance and legitimate interests as appropriate. Where personal data crosses a border we rely on Standard Contractual Clauses, the UK International Data Transfer Addendum, or an applicable adequacy decision.
5. Retention, return and deletion
Documents and derived work product are retained for the period your order form specifies. On termination they are exported in a portable form and destroyed on your instruction, subject to any retention you are yourself required to observe.
Review records are append-only during the term: a decision is superseded, never silently overwritten, because a record of who accepted a position is only useful if it cannot be edited afterwards.
6. Security and audit
Encryption in transit and at rest, per-customer segregation, unique user identification, logged access, and documented change control over the system and the models within it.
Customers may audit. Our current security posture, including what is not yet certified, is set out on the Trust page.
7. Personal data breach
On becoming aware of a breach affecting your documents we notify you without undue delay and within the period the DPA specifies, with the information you need for your own notifications — including any you owe a counterparty under the confidentiality terms of the agreement concerned.
8. Sub-processing
Sub-processors are listed on the Subprocessors page. You receive advance notice of any addition with a window to object, and every sub-processor with access to documents is bound by downstream terms no less protective than this agreement, including the prohibitions on training and pooling.
Pre-launch notice. These documents are drafted as realistic scaffolding for a RegTech vendor and have not been reviewed by counsel — which matters more than usual for a company selling to lawyers. Entity details, postal address, data protection officer and the subprocessor roster are placeholders pending incorporation. Do not rely on them as executed legal terms.