The policy states that personal data transferred from the EU/EEA to third countries is protected through Standard Contractual Clauses (SCCs) as approved by the European Commission.
This analysis describes what Tabnine'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 establishes the legal transfer mechanism for cross-border data flows from the EU/EEA, which is a requirement under GDPR Chapter V. Enterprise customers should confirm that executed SCCs are in place and reflect the current 2021 EU Commission SCC templates.
Interpretive note: The policy references SCCs but does not specify which module or whether UK-specific transfer mechanisms are separately addressed; this creates uncertainty for UK-user applicability.
The updated privacy policy no longer includes explicit language stating that Tabnine respects user privacy and the user's right to control how personal data is collected, used, and shared. This language removal does not necessarily change what data practices are authorized under other sections of the policy, but it does remove an aspirational commitment that was previously stated. The policy may continue to describe specific data practices, collection methods, and user controls elsewhere, but readers will no longer see this opening commitment to privacy and user control.
View change record →Under this clause, EU/EEA users' personal data transferred to non-EEA countries including the United States is covered by Standard Contractual Clauses. Users can request information about specific transfer safeguards by contacting privacy@tabnine.com.
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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.
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
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"When we transfer personal data outside of the European Economic Area, we ensure appropriate safeguards are in place, including the use of Standard Contractual Clauses approved by the European Commission.— Excerpt from Tabnine's Tabnine Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (international transfers), specifically Articles 46(2)(c) on Standard Contractual Clauses. The EU Commission's June 2021 SCCs are the current required template; use of pre-2021 SCCs may not satisfy GDPR transfer requirements. The European Data Protection Board's guidance on SCCs and supplementary measures following the Schrems II decision is also relevant. 2. GOVERNANCE EXPOSURE: Medium. Organizations must verify that Tabnine has executed current SCC templates with all relevant sub-processors receiving EU personal data, including the advertising and analytics vendors identified in the policy. Transfer Impact Assessments (TIAs) may be required for transfers to the United States. 3. JURISDICTION FLAGS: EU/EEA and UK users face the greatest exposure. UK GDPR requires equivalent transfer safeguards under the UK's International Data Transfer Agreement (IDTA) or UK Addendum to EU SCCs, which is distinct from the EU SCC framework. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers acting as EU data controllers should request copies of Tabnine's executed SCCs and any TIAs conducted for US transfers. DPAs with Tabnine should specify which SCC module applies (controller-to-processor or controller-to-controller) and cover all relevant processing activities including AI model training. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should request documentation of Tabnine's SCC execution status, confirm whether UK IDTA or Addendum is in place for UK users, and assess whether supplementary technical measures (such as encryption) are described. Data mapping should identify all non-EEA processing locations used by Tabnine and its sub-processors.
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This provision establishes the legal transfer mechanism for cross-border data flows from the EU/EEA, which is a requirement under GDPR Chapter V. Enterprise customers should confirm that executed SCCs are in place and reflect the current 2021 EU Commission SCC templates.
Under this clause, EU/EEA users' personal data transferred to non-EEA countries including the United States is covered by Standard Contractual Clauses. Users can request information about specific transfer safeguards by contacting privacy@tabnine.com.
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