Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
5.1 Privacy Policies - Subprocessors
FfilmshakeUpdated 17 Oct 2025
This document is a template for a Subprocessor List, designed to help a company identify and manage third-party entities authorized to process customer and personal data. It outlines the company's definition of customer data, including personal data as defined under GDPR, and provides a structured table for listing subprocessors, their processing activities, and locations. The template also includes guidance on how to update and customize the list.
Subprocessors
This document is taken from the GitHub website - more information about GitHub and its functions can be found at https://github.com/. Please note that many of the included provisions are designed for GitHub or similar site (such as for building and developing software with online communities), so they are not relevant to all types of business.
You can amend this document to be suitable for your own Community and purposes using the smart fields and customizing the bracketed sections. We recommend adding hyperlinks to your own policies and website pages - make sure your business has in place all the policies referred to here.
Please find the other specific Privacy Policies in this 'GitHub Site Policies for Startups' repository.
[company name] defines customer data as all data provided by the customer to [company name] through their use of [company name] services. Some customer data is personal data as defined under GDPR.
The [company name] Subprocessor List identifies subprocessors authorized to subprocess customer or personal data on behalf of [company name] to provide services to our Enterprise customers. This list is applicable for all [company name] services governed by the [[company name] Data Protection Agreement].
[company name] publishes the names of any new subprocessors for its online services at least [30 days] in advance of the subprocessor’s authorization to perform services that may involve access to customer data or personal data.
[To receive notifications of updates to this Subprocessor list, please follow the instructions provided in [insert link to instructions, if applicable]].
If you have questions about this list, please contact us at [insert email address or method of contact].
Complete the table below with the list of subprocessors used on your site. An example has been provided in row 2 from the GitHub site.
Name of Subprocessor | Description of Processing | Location of Processing | Corporate Location |
[Amazon Web Services (AWS)] | [Cloud Hosted Infrastructure and Data Hosting] | [United States] | [United States] |
United States note
This version is drafted for US law generally. Contract, employment and consumer rules vary by state — for example on non-competes and at-will employment. Tell GitLaw which state applies and it adjusts the draft.
Jurisdiction
European Union
United States of America
Document info
HTML document. Document created on Tue Jul 15th, 2025. Last updated on Fri Oct 17th, 2025.
This document is public
Licensed under CC BY 4.0 (Attribution).
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