Tabnine Privacy Policy

This document is Tabnine's privacy policy governing the collection, use, storage, and sharing of personal data by Tabnine Ltd. in connection with its AI code assistant products and website, operating under a consent and legitimate interests framework referencing GDPR, CCPA, and related frameworks. The policy states that Tabnine collects identifiers, contact information, professional information, device and browser data, usage and telemetry data, code snippets submitted as prompts, and payment information, and authorizes sharing this data with analytics, advertising, marketing, CRM, and infrastructure service providers. A notable provision states that code snippets submitted by users may be processed to improve Tabnine's AI models unless the user has a paid plan with telemetry disabled or opts out, which creates a materially distinct treatment between free and paid users regarding training data use; the policy asserts this processing occurs under legitimate interests, a legal basis that may be subject to challenge under GDPR's balancing test, particularly for enterprise customers processing proprietary or sensitive code. The policy references GDPR (including data subject rights for EU/EEA users), CCPA (including opt-out rights for California residents), and engages applicable cross-border data transfer mechanisms including Standard Contractual Clauses; compliance teams at organizations deploying Tabnine should evaluate whether employee code submissions constitute personal data or confidential business information subject to additional obligations, and whether the telemetry opt-out mechanism is sufficiently prominent and accessible to satisfy GDPR transparency requirements.