Supabase · Supabase Privacy Policy · View original document ↗

Customer Data Processor Carve-Out

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

The policy states that personal data submitted through Supabase's platform by enterprise customers relating to their own end users is processed by Supabase as a data processor under a separate data processing addendum, and this privacy notice does not govern that processing.

This analysis describes what Supabase'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 end users of applications built on Supabase are not covered by this privacy notice, placing the primary disclosure obligation on the Supabase customer (the application operator) rather than Supabase itself. This has direct implications for enterprise customers who must maintain their own adequate privacy disclosures and ensure their DPA with Supabase is GDPR Article 28 compliant.

Recent Activity

This document changed recently

Medium May 15, 2026

The updated policy discloses that Supabase may use business contact information, including email domains, to identify organizations for sales and marketing outreach. The policy now explicitly states that personal information will be shared with Customer.io, a marketing communications service provider. For marketing communications, the policy relies on user consent for three purposes: sending marketing messages, using approximate location information to determine relevant communications, and combining personal information from different sources for relevance determination. These three consents operate independently, meaning you can grant or withdraw any of them without affecting the others. You can manage these marketing-related consents separately through the consent mechanisms available in your account or in response to marketing communications.

View change record →

Consumer impact (what this means for users)

Under this clause, individuals whose personal data is processed through applications built on Supabase are directed to consult the privacy notice of the application operator rather than Supabase's own policy. The agreement establishes that Supabase's obligations for such data are governed by a separate data processing addendum with the relevant enterprise customer.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

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▸ View Original Clause Language DOCUMENT RECORD
"
Our Service allows customers to submit, manage or otherwise use content relating to others, such as end users of applications built and managed through the Service or their employees and contractors ("Customer Data"). We use such Customer Data primarily as a processor, meaning we process such Customer Data on behalf of and under the instructions of the relevant customer, in accordance with our data processing addendum. This Privacy Notice does not apply to such processing; if you believe your personal information has been included in any Customer Data, we recommend you read the Privacy Notice of the respective customer.

— Excerpt from Supabase's Supabase Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28 (processor obligations), which requires a written contract between controller and processor specifying the nature and purpose of processing. The referenced data processing addendum is the operative document for GDPR compliance in this context. The UK GDPR imposes equivalent requirements. For California customers, CCPA requires service provider contracts to include specific restriction clauses. Enforcement authorities are EU supervisory authorities, the UK ICO, and the California Privacy Protection Agency. 2) GOVERNANCE EXPOSURE: High for enterprise customers. The carve-out places full controller-side disclosure and compliance obligations on Supabase customers who deploy the platform to serve their own end users. Any gap in those customers' privacy notices or DPA terms creates compliance exposure at the customer level. 3) JURISDICTION FLAGS: EU/EEA and UK deployments require GDPR Article 28-compliant DPAs between Supabase and each enterprise customer. California-based customers must ensure the DPA includes CCPA service provider restrictions. Sub-processor chains involving international transfers require separate transfer mechanism documentation. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams at organizations using Supabase should confirm that the referenced data processing addendum has been executed and reviewed for GDPR Article 28 and CCPA service provider compliance. They should also assess whether Supabase's sub-processor list is disclosed and whether advance notice of sub-processor changes is contractually provided. 5) COMPLIANCE CONSIDERATIONS: Enterprise customers should update their own privacy notices to disclose Supabase's role as a sub-processor. Data mapping documentation should reflect the controller/processor relationship and the scope of data categories processed. Periodic audits of the DPA and sub-processor list are advisable given the operational significance of the platform.

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 privacy practices, including failure of controllers to adequately disclose third-party processing arrangements to consumers.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Supabase Privacy Policy
Entity
Supabase
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-007512
Document ID
CA-D-00682
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2612a6b321182bf3baea7bed73960fe4fa4a2105a6ce3e8fcb5b9415b1db09bf
Analysis generated
May 21, 2026 03:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Supabase
Document: Supabase Privacy Policy
Record ID: CA-P-007512
Captured: 2026-05-21 03:12:55 UTC
SHA-256: 2612a6b321182bf3…
URL: https://conductatlas.com/platform/supabase/supabase-privacy-policy/customer-data-processor-carve-out/
Accessed: June 27, 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 Supabase's Customer Data Processor Carve-Out clause do?

This provision establishes that end users of applications built on Supabase are not covered by this privacy notice, placing the primary disclosure obligation on the Supabase customer (the application operator) rather than Supabase itself. This has direct implications for enterprise customers who must maintain their own adequate privacy disclosures and ensure their DPA with Supabase is GDPR Article 28 compliant.

How does this clause affect you?

Under this clause, individuals whose personal data is processed through applications built on Supabase are directed to consult the privacy notice of the application operator rather than Supabase's own policy. The agreement establishes that Supabase's obligations for such data are governed by a separate data processing addendum with the relevant enterprise customer.

Is ConductAtlas affiliated with Supabase?

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