Sourcegraph Cody · Sourcegraph Privacy Policy · View original document ↗

Customer Personal Data Exclusion

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Data that enterprise or business customers submit through Sourcegraph's business products is governed by separate contracts with those customers, not by this public privacy policy.

This analysis describes what Sourcegraph Cody'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that the consumer-facing privacy protections in this policy do not apply to data processed under enterprise agreements, meaning individual users in organizational deployments may have different and separately negotiated data protections.

Consumer impact (what this means for users)

Individual users whose organizations have deployed Sourcegraph under a business agreement should review their employer's data processing agreement with Sourcegraph rather than this policy to understand how their data is handled, as this policy explicitly excludes Customer Personal Data from its scope.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
This Privacy Policy does not apply to Customer Personal Data, which we process on behalf of customers to our business offerings. Our use of that data is instead governed by our customer agreements.

— Excerpt from Sourcegraph Cody's Sourcegraph Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: This provision engages GDPR controller-processor distinctions, under which Sourcegraph acts as a data processor for business customers who are controllers of Customer Personal Data. CCPA similarly distinguishes between service provider relationships and direct data collection. Enforcement authorities in the EU (national data protection authorities) and US (FTC, State AGs) may examine whether the boundary between Customer Personal Data and data covered by this policy is clearly defined and consistently implemented. 2) GOVERNANCE EXPOSURE: High. The exclusion of Customer Personal Data from this policy creates a governance dependency on the content of individual customer agreements. If customer agreements do not adequately address data processing obligations (sub-processing, deletion, breach notification, international transfers), gaps may exist that are not visible from this public policy. 3) JURISDICTION FLAGS: EU/EEA enterprise customers must ensure their data processing agreements with Sourcegraph satisfy GDPR Article 28 requirements for processor contracts. UK GDPR imposes equivalent requirements post-Brexit. California CCPA requires written contracts with service providers. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams should confirm that existing customer agreements with Sourcegraph explicitly cover all data flows, including AI-assisted coding features such as Cody that may process code-embedded personal data. The subprocessors page referenced in the policy should be reviewed to confirm downstream processors are identified and covered by appropriate contractual safeguards. 5) COMPLIANCE CONSIDERATIONS: Teams should audit whether their customer agreements include data processing addenda meeting GDPR Article 28 standards, and should clarify with Sourcegraph which product features generate Customer Personal Data versus data governed by this public policy.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over deceptive or unfair practices related to privacy representations, including the scope and accuracy of privacy policy disclosures for US consumers.
    File a complaint →

Provision details

Document information
Document
Sourcegraph Privacy Policy
Entity
Sourcegraph Cody
Document last updated
May 12, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011841
Document ID
CA-D-00799
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
df2d4196ecea360b04ad9684b8e596ac2cfeb41cb2be50ace2b878d7c3dd599f
Analysis generated
May 12, 2026 15:34 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Sourcegraph Cody
Document: Sourcegraph Privacy Policy
Record ID: CA-P-011841
Captured: 2026-05-12 15:34:28 UTC
SHA-256: df2d4196ecea360b…
URL: https://conductatlas.com/platform/sourcegraph-cody/sourcegraph-privacy-policy/customer-personal-data-exclusion/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Sourcegraph Cody's Customer Personal Data Exclusion clause do?

This provision establishes that the consumer-facing privacy protections in this policy do not apply to data processed under enterprise agreements, meaning individual users in organizational deployments may have different and separately negotiated data protections.

How does this clause affect you?

Individual users whose organizations have deployed Sourcegraph under a business agreement should review their employer's data processing agreement with Sourcegraph rather than this policy to understand how their data is handled, as this policy explicitly excludes Customer Personal Data from its scope.

Is ConductAtlas affiliated with Sourcegraph Cody?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Sourcegraph Cody.