The policy authorizes Replit to share user information, including user-generated code and usage data, with machine learning companies retained as service providers in connection with providing the Services.
This analysis describes what Replit'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
This provision authorizes disclosure of user data, including code, to machine learning service providers. This has operational significance for developers whose code may contain proprietary logic, credentials, or sensitive data, and for enterprise customers evaluating the scope of data access granted to Replit's vendor ecosystem.
Interpretive note: The policy discloses machine learning companies as a category of service provider but does not identify specific vendors or the specific data categories each receives; the full scope requires review of Replit's separately published Subprocessors list.
The updated policy organizes personal data collection into specific categories: registration data (name, email, phone), content created (code, files, prompts), collaboration data (teams, workspaces, permissions), usage logs (pages viewed, searches, interactions), communications (messages, attachments), payment data (card details, billing address, subscription type, collected by third-party processors), device data (IP address, browser type, operating system, device identifiers), and general location inference from IP address (with explicit statement that precise location requires consent). The policy states it 'may collect certain Personal Data' but does not materially expand the types of data collection beyond the prior version's framework. The removal of the explicit Data Processing Agreement reference may affect how EU/UK/Switzerland users exercise data rights, though the policy now cross-references the Terms of Service and indicates DPA compliance may be addressed elsewhere.
View change record →This provision explicitly permits sharing with machine learning providers, directly enabling AI training use cases with third parties beyond Replit's own models.
View full change record →Under this clause, user-generated content including code, along with registration, device, usage, and location data, may be shared with machine learning companies as part of Replit's service provider network. The policy does not specify which machine learning providers receive which categories of data or for what specific machine learning purposes.
Cross-platform context
See how other platforms handle Machine Learning Provider Data Sharing and similar clauses.
Compare across platforms →"We may share any information we receive with vendors retained in connection with the provision of our Services and that process your information on our behalf. These entities may include analytics, billing, legal support, marketing, security, machine learning, and fraud prevention companies.Excerpt from Replit's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR processor and sub-processor disclosure requirements for EEA and UK users; Replit references a separate DPA for entity customers in those regions, which should be reviewed to confirm sub-processor …
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This provision authorizes disclosure of user data, including code, to machine learning service providers. This has operational significance for developers whose code may contain proprietary logic, credentials, or sensitive data, and for enterprise customers evaluating the scope of data access granted to Replit's vendor ecosystem.
Under this clause, user-generated content including code, along with registration, device, usage, and location data, may be shared with machine learning companies as part of Replit's service provider network. The policy does not specify which machine learning providers receive which categories of data or for what specific machine learning purposes.
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