Cursor publishes a list of all third-party vendors that process user data and reviews each one annually; the list is available at trust.cursor.com/subprocessors.
This analysis describes what Cursor's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The subprocessor list and annual review commitment are operationally significant for enterprise customers who need to track third-party data flows for GDPR Article 28 compliance or internal vendor risk programs.
Interpretive note: The document does not specify whether customers receive advance notice of subprocessor changes or have objection rights, which are material gaps for GDPR Article 28 compliance assessment.
This provision states that Cursor maintains and publishes a list of vendors that may process user data, including code, and reviews each vendor annually; enterprise customers can consult trust.cursor.com/subprocessors to identify all entities that may receive their data.
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to object to profiling activities based on our own legitimate interests
"Our list of subprocessors is published on our trust portal. Each subprocessor is evaluated under our vendor risk management program and re-reviewed annually. Cursor respects model blocklists and will not send requests to models on a blocklist.Excerpt from Cursor's Security Practices
(1) REGULATORY LANDSCAPE: GDPR Article 28 requires controllers to use only processors that provide sufficient guarantees and to impose sub-processor obligations contractually.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The subprocessor list and annual review commitment are operationally significant for enterprise customers who need to track third-party data flows for GDPR Article 28 compliance or internal vendor risk programs.
This provision states that Cursor maintains and publishes a list of vendors that may process user data, including code, and reviews each vendor annually; enterprise customers can consult trust.cursor.com/subprocessors to identify all entities that may receive their data.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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