Sourcegraph Cody · Sourcegraph Privacy Policy · View original document ↗

Data Sharing with Service Providers and Subprocessors

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Document Record

What it is

Sourcegraph shares your personal information, including the prompts you submit when writing code, with third-party service providers that help operate the services, subject to restrictions on how those providers can use the data.

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 confirms that code prompts and related content submitted to Sourcegraph's AI coding features are shared with third-party subprocessors, which is material for users submitting proprietary or sensitive code.

Consumer impact (what this means for users)

Code prompts and other content you submit when using Sourcegraph's AI-assisted coding features are shared with third-party subprocessors listed at sourcegraph.com/terms/subprocessors. Users submitting proprietary code should review the subprocessors list to understand which third parties may process their code content.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Visit the Sourcegraph Subprocessors page to review the current list of third parties that may process your personal information, including code prompts submitted to AI coding features.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Our service providers process your Personal Information as needed to provide our Services to you, including your content and processing prompts to help you write code. They may only process your Personal Information pursuant to our instructions and to perform their duties to us. See our Subprocessors page for a list of our service providers.

— Excerpt from Sourcegraph Cody's Sourcegraph Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: Sharing personal data with service providers engages GDPR Article 28 processor obligations and CCPA service provider requirements. The specific disclosure that prompts used to help write code are shared with subprocessors is material under both frameworks, as code may contain personal data or trade secrets. EU/EEA data transfers to subprocessors outside the EEA require adequate transfer mechanisms under GDPR Chapter V. 2) GOVERNANCE EXPOSURE: Medium. The policy references a separate subprocessors page rather than listing subprocessors inline, which means the list may change without formal policy amendment. Users and enterprise customers should monitor the subprocessors page for changes that could affect their data protection posture. 3) JURISDICTION FLAGS: EU/EEA users should confirm that subprocessors receiving personal data have adequate transfer mechanisms in place (Standard Contractual Clauses or equivalent). California users should confirm that subprocessors qualify as service providers under CCPA rather than third parties. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should conduct vendor assessments on the subprocessors listed, particularly AI model providers that may process code prompts. The policy's restriction that subprocessors may only process data pursuant to Sourcegraph's instructions should be verified against the actual subprocessor agreements. 5) COMPLIANCE CONSIDERATIONS: Legal teams should implement a process for monitoring changes to the subprocessors page and assessing the data protection implications of any additions. Data processing agreements should include provisions requiring Sourcegraph to notify customers of subprocessor changes.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has jurisdiction over consumer data sharing practices and representations made to consumers about how their data is handled by third parties.
    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-011843
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-011843
Captured: 2026-05-12 15:34:28 UTC
SHA-256: df2d4196ecea360b…
URL: https://conductatlas.com/platform/sourcegraph-cody/sourcegraph-privacy-policy/data-sharing-with-service-providers-and-subprocessors/
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 Data Sharing with Service Providers and Subprocessors clause do?

This provision confirms that code prompts and related content submitted to Sourcegraph's AI coding features are shared with third-party subprocessors, which is material for users submitting proprietary or sensitive code.

How does this clause affect you?

Code prompts and other content you submit when using Sourcegraph's AI-assisted coding features are shared with third-party subprocessors listed at sourcegraph.com/terms/subprocessors. Users submitting proprietary code should review the subprocessors list to understand which third parties may process their code content.

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.