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Data Processing Agreement

Last updated: 27 September 2026

1. Definitions

"Customer Data" means any AWS billing data, security metadata, or account configuration data processed by Refine on behalf of Customer. "Processing" has the meaning given in applicable data protection law.

2. Roles of the parties

Customer is the Data Controller. Refine is the Data Processor. Refine processes Customer Data only on documented instructions from Customer.

3. Nature and purpose of processing

Refine processes Customer Data to (a) read AWS cost and usage information via the read-only IAM role Customer grants; (b) perform security posture analysis; (c) generate cost optimization recommendations; (d) detect anomalies; (e) deliver scheduled reports.

4. Sub-processors

The current list is maintained on our sub-processor list. We will provide notice via email to Customer's primary contact at least 30 days before engaging a new sub-processor. Customer may object in writing within that period.

5. Security measures

Refine implements the following technical and organizational measures:

  • Encryption in transit (TLS 1.2 or higher) and at rest (AES-256 for the Customer Data Refine stores in its database tables, file storage and backups; AWS credentials Customer provides are additionally encrypted with a dedicated AWS KMS key)
  • Read-only access to Customer AWS accounts: the connector is an IAM role that only Refine's AWS account can assume, with Customer's External ID, granting billing, security-audit and export-bucket read permissions only; Refine never modifies Customer resources. A connection made before IAM roles were available uses an access key, which is encrypted before it reaches Refine and stored only in that encrypted form. Customer can revoke either at any time
  • Audit logging of all administrative actions
  • Annual review of access controls and key rotation
  • Vulnerability disclosure program at info@habilelabs.io

6. Data retention and deletion

Customer Data is retained for as long as the Customer's account is active. Alerts and notifications are deleted automatically after 90 days. Customer may delete Customer Data at any time from within the Service, or request deletion by emailing info@habilelabs.io; Refine will process the request within 5 business days and confirm in writing. Deleted Customer Data is not removed from Refine’s encrypted daily database backups taken before the deletion; those backups expire, and are deleted, within 10 days of it.

7. International data transfers

Refine processes Customer Data primarily in AWS region ap-south-1 (Mumbai). Where Customer Data is transferred outside the EEA, Refine relies on Standard Contractual Clauses approved by the European Commission.

8. Data subject rights

Refine will assist Customer in responding to requests from Data Subjects exercising their rights under applicable data protection law (access, rectification, erasure, portability). Requests received directly by Refine will be forwarded to Customer for handling.

9. Personal data breach notification

In the event of a Personal Data Breach, Refine will notify Customer without undue delay and in any event within 48 hours of becoming aware of the breach.

10. Audit rights

Customer may, no more than once per year and on reasonable notice, request information sufficient to demonstrate compliance with this DPA. Refine will provide reasonable evidence including security-attestation documentation when available.

11. Termination

On termination of the underlying agreement, Refine will, at Customer's option, return or delete all Customer Data within 30 days unless retention is required by law.

12. Governing law

This DPA is governed by the laws specified in the underlying agreement between Customer and Refine.

13. Contact

Privacy contact: info@habilelabs.io

Need a signed copy?

Email info@habilelabs.io with your company name and counter-signing contact. Custom DPAs are available on the Enterprise plan.

Have other privacy or compliance questions?

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Refine is built and supported by HabileLabs, an AWS Advanced Tier Services Partner.