Third-Party Sub-Processor and Data Sharing

What it is

Tabnine shares your data with outside companies that help run its service, such as cloud hosting providers, analytics tools, payment processors, and marketing platforms. You can ask for a list of those companies.

Why it matters (compliance & governance perspective)

The policy authorizes data sharing with a range of third-party service providers, and the sub-processor list is available only upon request rather than being published directly, which limits user visibility into which specific vendors receive their data.

Consumer impact (what this means for users)

Personal data including identifiers, usage activity, and potentially code inputs may be transmitted to cloud infrastructure, analytics, payment, and marketing vendors; the specific companies involved are not listed in the policy and must be requested separately.

What you can do

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: GDPR Article 28 requires that data controllers use only processors that provide sufficient guarantees regarding GDPR-compliant processing, and that processing be governed by a binding contract. The absence of a published sub-processor list in the policy itself may complicate customers' ability to fulfill their own sub-processor notification obligations under Article 28(2). CCPA and CPRA require disclosure of categories of third parties with whom personal information is shared. The FTC Act applies to the accuracy of these disclosures. 2) GOVERNANCE EXPOSURE: Medium. The policy's statement that a sub-processor list is available upon request rather than publicly published is operationally significant for enterprise customers who need to conduct their own data protection impact assessments or fulfill regulatory disclosure obligations. The inclusion of business partners in the sharing authorization is broader than strictly necessary for service delivery and may warrant scrutiny. 3) JURISDICTION FLAGS: EU/EEA customers must confirm that data transfers to sub-processors in non-adequate third countries are covered by appropriate transfer mechanisms (Standard Contractual Clauses or equivalent). California residents can request disclosure of third-party categories under CPRA. UK customers require similar transfer mechanism assessments under UK GDPR and the UK International Data Transfer Agreement framework. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise contracts should include a contractual right to receive advance notice of sub-processor changes, consistent with GDPR Article 28 practice, and a right to object. Procurement teams should request the current sub-processor list as part of onboarding due diligence and assess whether any sub-processors operate in jurisdictions without adequate data protection. 5) COMPLIANCE CONSIDERATIONS: Legal teams should request and retain the sub-processor list, map data flows to each vendor, and confirm appropriate transfer mechanisms are in place. The sharing authorization with business partners should be reviewed to determine whether it constitutes a sale or sharing of personal information under CPRA, triggering additional opt-out rights.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Code Snippet Collection and AI Model Training (Free/Pro Users) high
• Personal Data Categories Collected medium
• User Rights (GDPR, CCPA, and Other Jurisdictions) medium
• Data Retention medium
• International Data Transfers medium
• Cookies and Tracking Technologies medium

Related Analysis

• Meta Removed 438 Sentences From Its Privacy Policy. Here Is What Disappeared.

  ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.

• 23andMe Is Bankrupt. What Happens to Your DNA Now?

  Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.