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| 0 | Privacy Policy PRIVACY POLICY Last updated: October 21, 2025 Thank you for choosing to be part of our community at Exafunction, Inc. | 0 | Menu Close Home Careers Research Blog Contact Devin Windsurf Home Careers Research Blog Contact Devin Windsurf Privacy Policy Last updated: March 9, 2026 This Privacy Policy explains how Cognition AI, Inc (“ we ”, “ our ” or “ us ”) collect, use, disclose, and safeguard your information when you use visit our website (www.cognition.ai), our software-as-a-service offerings that we make available to individuals and enterprise customers (e.g., Devin and Windsurf), along with any associated software, apps and websites (collectively, the “ Services ”). |
| 1 | (" Company ," " we ," " us ," or " our "). | 1 | It is important that you understand how we use your information. |
| 2 | We are committed to protecting your Personal Information and your right to privacy. | 2 | You should read this page in full, but below are key highlights and some helpful links: Our goal is to simplify your experience. |
| 3 | If you have any questions or concerns about this Privacy Policy or our practices with regard to your Personal Information, please contact us at privacy@windsurf.com . | 3 | If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Services. |
| 4 | This Privacy Policy describes how we might use your information if you: Visit our website at windsurf.com or use any of our other Services, as described further below Engage with us in other related ways ― including any sales, marketing, or events In this Privacy Policy, if we refer to: " Personal Information ," we are referring to information that alone or in combination with other information in our possession could be used to identify you " Website ," we are referring to any website of ours that references or links to this policy, including www.windsurf.com " Services ," we are referring to our Website, and other related services, including our downloadable extension, application programming interfaces (" APIs "), associated software, tools, developer services, data and documentation The purpose of this Privacy Policy is to explain to you in the clearest way possible what Personal Information we collect, how we use it, and what rights you have in relation to it. | 4 | We collect and use your information in order to provide and improve our Services and your experience, protect the security and integrity of our platform, and meet our legal obligations. |
| 5 | If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately. | 5 | To learn more, explore Section 1. |
| 6 | By using our Services, you agree to the collection, use, disclosure and procedures this Privacy Policy describes. | 6 | Information We Collect and Section 2. |
| 7 | Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service . | 7 | How We Use Your Information . |
| 8 | This Privacy Policy also applies to the residents of certain U.S. states that have enacted comprehensive privacy laws and explains how we collect and process information about you as a controller and how you can exercise your rights under those privacy laws. | 8 | We share your information with trusted third parties and service providers in order to offer our Services, fulfill legal requirements and for the purposes set out more fully below. |
| 9 | If you are a resident of California, please also review our California Resident Privacy Notice for more information about the types of personal information we collect and disclose, as well as how to exercise your rights under California law. | 9 | If you have any questions, or to exercise any available rights, please contact us at privacy@cognition.ai . 1. |
| 10 | We are a data controller with respect to data collected and otherwise processed in connection with our Website and Services. | 10 | Information we collect We collect, and in the past 12 months have collected, the following personal information about you: Information you provide to us Description Contact Information First name, last name, email address, phone number, and company name (if any). |
| 11 | However, in certain circumstances we may agree to process information in the role of a processor or service provider on behalf of our customers (for example, on behalf of your employer). | 11 | User Content Any personal information collected when you use our Services, including personal information that may be provided in the input, file uploads, feedback or output. |
| 12 | When we act as a processor, this Privacy Policy will not apply to that information, as our customers are the data controllers and their privacy policies will apply to the processing of your personal information. | 12 | Additional information and communications you submit to us Any communications that we exchange, including communications with interfaces such as our chatbots, survey responses, or feedback. |
| 13 | We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Policy. | 13 | Account Information Email address, password, GitHub/GitLab or other git provider username. |
| 14 | If you do not provide your Personal Information when requested, you may not be able to use our Services if that Personal Information is necessary to provide you with our Services or if we are legally required to collect it. | 14 | Voice input If you use voice features, we process the audio to generate transcriptions or commands. |
| 15 | TABLE OF CONTENTS WHAT PERSONAL INFORMATION DO WE COLLECT? | 15 | Audio is deleted after transcription unless otherwise stated. |
| 16 | HOW DO WE USE YOUR PERSONAL INFORMATION? | 16 | Personal information does not include information that has been de-identified, anonymized or aggregated. |
| 17 | LEGAL BASES FOR PROCESSING EUROPEAN PERSONAL INFORMATION WILL YOUR PERSONAL INFORMATION BE DISCLOSED TO ANYONE? | 17 | When data is de-identified or anonymized, we maintain it in that form and do not attempt to re-identify the information. 2. |
| 18 | TO WHOM WILL YOUR PERSONAL INFORMATION BE DISCLOSED? | 18 | How we use your information We use your personal information to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and customized experience as you use our Services, and for legal compliance, and loss prevention. |
| 19 | DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? | 19 | We only use your account password to create and maintain your account and to provide you with the Services. |
| 20 | IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY? | 20 | Learn more about how we use your personal information and our legal basis for each such use case below. |
| 21 | HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION? | 21 | Why and how we use your information Information categories used Legal basis of processing (where applicable) To create and maintain your account Basic Information and Account Information Necessary to perform our contract with you To provide you with Services Basic Information, Account Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us Necessary to perform our contract with you To provide customer support Basic Information, Account Information, Communications, Services usage data (including location information), App, browser, and device information We rely on our legitimate interests or those of third parties (like other users and in some cases, the general public) where they are not outweighed by your rights and freedoms. |
| 22 | THIRD PARTIES HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE? | 22 | In the EEA and UK, you have the right to object to, and seek restrictions of this processing (“Legitimate Interests”) — specifically, our interest in being responsive to your requests and ensuring you have the best use of the Services To send Service communications Basic Information, Account Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us Necessary to perform our contract with you. |
| 23 | DO WE COLLECT PERSONAL INFORMATION FROM MINORS? | 23 | Legitimate Interests — specifically, our interest in ensuring you have the best use of the Services To promote safety, security, and integrity of our Services Basic Information, Account Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us Legitimate Interests — specifically, our interest in ensuring and maintain the effective operations and delivery of the Services To comply with legal and regulatory obligations. |
| 24 | WHAT ARE YOUR PRIVACY RIGHTS? | 24 | We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities Basic Information, Account Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us To comply with our legal obligations. |
| 25 | CONTROLS FOR DO-NOT-TRACK FEATURES DO WE MAKE UPDATES TO THIS NOTICE? | 25 | Legitimate Interests — specifically, our interest in complying with legal obligations, requests and our corporate responsibilities where we operate To customize your experience with our Services and otherwise improve our Services including, depending on the terms that apply to your use of the Services, using User Content to train, fine tune and improve the models that power our Services. |
| 26 | HOW CAN YOU CONTACT US ABOUT THIS NOTICE? | 26 | Basic Information, Account Information, Communications, App, browser, and device information, Services usage data, and User Content Legitimate Interests — specifically, it is in our interest to understand how you interact with the Services in order to customize and/or improve our products and Services, and the models that power our Services, and enable accurate and reliable reporting Where not otherwise required by law, and depending on the circumstances, we may preserve and share your information: in response to requests from third parties, law enforcement, or other governmental authorities; to promote the safety, security, and integrity of the Services, network, our users, employees, and the public Basic Information, Account Information, Communications, App, browser, and device information, Services usage data Legitimate Interests — specifically, it is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of the Services, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our personnel and property or the Service) our users or others, to defend our legal rights and resolve disputes, to secure our platform and network, to verify accounts and activity, to combat harmful conduct, to prevent and address fraud, abuse and other bad experiences, to prevent death or imminent bodily harm To research and innovate Basic Information, Account Information, Communications, Service Usage Data Legitimate Interests — specifically, it is in our interest and our users interest to improve and iterate our Services through information obtained from users, surveys, reviews, and feedback 3. |
| 27 | HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU? 1. | 27 | How and why we share your information We do not sell or share your personal information with third parties for targeted advertising purposes, nor have we done so in the past 12 months. |
| 28 | WHAT PERSONAL INFORMATION DO WE COLLECT? | 28 | We also do not have actual knowledge that we sell or share for targeted advertising purposes personal information about individuals under 16 years old. |
| 29 | Personal information you disclose to us In Short: We collect personal information that you provide to us. | 29 | We work with service providers and other third parties to help us provide our Services, and as a result we need to provide certain information with these third parties as described below. |
| 30 | Registration Information. | 30 | We disclose, and in the past 12 months, we've disclosed, the categories of personal data set forth in Section 1 with the following categories of third parties: Third Party Service Providers — We provide personal information to third party service providers who help us provide our Services. |
| 31 | We collect Personal Information that you voluntarily provide to us when you register an account on the Website, such as your name, email address, phone number, information regarding your role and work, Github username, and password. | 31 | Other Third Parties — Certain features allow you to display or share information with other users or third parties. |
| 32 | If you sign up using another account, such as a social media account, we will also receive information from those services such as your name and email address. | 32 | For example, you may share Devin AI conversations with other users via shared links. |
| 33 | Communications Information. | 33 | Be sure you trust any user or third party with whom you share information. |
| 34 | We collect Personal Information when you use our Services or otherwise contact us, such as your name, email address, job titles, contact or authentication data, phone numbers, usernames, passwords, newsletter subscription status, and other similar information. | 34 | Professional Advisors, authorities, and regulators — We share your information with our advisors, regulators, tax authorities, law enforcement, and government agencies to: Respond pursuant to applicable law or regulations, court orders, legal process or government requests; Comply with our reporting and information sharing obligations and regulatory authorities; Detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and Protect the rights, property, safety of us, our users, or others, including to prevent death or imminent bodily harm. |
| 35 | When you communicate with us online, third party vendors receive and store these communications on our behalf. | 35 | Your employer or related organisation — If you create an account using an email address belonging or relating to your employer or another organisation, we may share the fact that you have an account and certain account information (such as your email address) with your employer or organisation to, for example, enable you to be added to their business or enterprise account. |
| 36 | The Personal Information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. | 36 | In addition, administrators of any enterprise or business account may be able to access certain information associated with your account, including your User Content, and be able to control your account and such information. |
| 37 | All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Personal Information. | 37 | To our affiliates or others within our corporate group , as a matter of our legitimate interests to efficiently provide the Services. |
| 38 | Careers Information. | 38 | Asset Transfer or Company Acquisition — We may choose to buy or sell assets, and may share and/or transfer information about our users in connection with the evaluation of and entry into such transactions. |
| 39 | If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. | 39 | Also, if we (or our assets) are acquired, merged, reorganized, or if we go out of business, enter bankruptcy, or go through some other change of control or similar event, your personal information could be transferred in connection with that transaction. |
| 40 | We will collect the information you choose to provide on your resume, such as your education and employment experience. | 40 | When you request or direct us to disclose information , with your consent or to perform our contract with you. |
| 41 | You may also apply through a third-party service, such as LinkedIn. If you do so, we will collect the information you make available to us through that service. | 41 | Our Services may contain links to other websites not operated or controlled by Cognition AI, Inc, including social media services (“Third-Party Sites”). |
| 42 | Testimonial Information. | 42 | The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. |
| 43 | If you decide to send us a testimonial directly or through our third-party provider, we may receive your name and contents of your review, such as photos, text, and videos. | 43 | By providing these links we do not imply that we endorse or have reviewed these sites. |
| 44 | Information we collect when you use our Services. | 44 | Please contact the Third Party Sites directly for information on their privacy practices and policies. 4. |
| 45 | In Short: Some Personal Information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you use our Services. | 45 | Security We implement commercially reasonable technical, administrative, and organizational measures intended to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. |
| 46 | We automatically collect certain information when you visit, use or navigate our Services. | 46 | However, these measures are not a guarantee of absolute security and you acknowledge and accept that your use of our Services is ultimately at your own risk. 5. |
| 47 | This information does not reveal your specific identity (like your name or contact information) but may include device, hardware, and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. | 47 | Retention We retain your personal information as needed to provide our Service to you, comply with legal obligations, or protect ours or others interests. |
| 48 | This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. | 48 | How long we retain personal information includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, or information preservation requirements. |
| 49 | Like many businesses, we also collect information through cookies and similar technologies. | 49 | We also keep certain information where necessary to protect the safety, security, and integrity of our Services or users. |
| 50 | The information we collect when you use our Services includes: Log and Usage Information . | 50 | In line with these considerations, we delete information that is no longer needed for the above purposes or when you request deletion of your information. 6. |
| 51 | Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services, and which we record in log files. | 51 | Children's personal information The Services are not intended for children, and we do not knowingly request or collect any personal information from children. |
| 52 | Depending on how you interact with us, this log data may include your IP address, device information, browser and/or integrated development environment (IDE) type and settings, operating system, and information about your activity (such as the features you have enabled and/or used and the numbers and frequencies of actions and date/time stamps associated with your usage, pages and files viewed, searches, chats sent, commands triggered or accepted, characters written, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings). | 52 | As set out in our Terms, users must be at least 18 years old in order to access the Services. 7. |
| 53 | Prompts and Outputs Information. | 53 | International transfers To facilitate our operations, Cognition, our third-party partners, and service providers may transfer, store, and process your personal information throughout the world, including the EU, UK and the US. |
| 54 | Our Services allow you to submit text to the Services ("Prompts"), which generate responses based on your Prompts ("Outputs"). | 54 | If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon certain legal mechanisms to facilitate these transfers of your personal information, including in some cases the European Commission's Standard Contractual Clauses and relevant local clauses (e.g., the UK's International Data Transfer Addendum) to facilitate the international and onward transfer of European personal data to third countries. |
| 55 | We will collect any information you choose to provide in your Prompts and this information may be reproduced in the Outputs. | 55 | You can contact us at the address below to view a copy or request more information about these mechanisms. 8. |
| 56 | Prompts and Outputs may constitute or contain Personal Information, depending on how it is associated with your account and other information we maintain about you. | 56 | Your privacy rights and choices Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. |
| 57 | Voice Commands. | 57 | If any of the rights listed below are not provided for under law for your jurisdiction, we have absolute discretion in providing these rights. |
| 58 | Our Services allow you to input your voice to generate Prompts and other text transcriptions. | 58 | Right to access/know and portability : You may have the right to request that we provide you a copy of your personal information held by us, or for details relating to the ways in which we use and disclose your personal information, and how we have used or disclosed your personal information in the past. |
| 59 | We process your voice audio to convert it into Prompts and other text transcriptions and then discard the audio after the processing is complete. | 59 | You may also have the right to request that we provide certain personal information in a structured, commonly used, machine-readable format and make this available to you or a designated third party. |
| 60 | We retain and use audio text transcriptions as Log and Usage Information. | 60 | Right to deletion/erasure : You may have the right to request to erase your personal information. |
| 61 | Information we receive from other sources. | 61 | If you end your Services, we will retain or delete information associated with your account as described in Section 5. |
| 62 | In Short: we may receive your Personal Information from other sources. | 62 | Right to rectification/correction : You may have the right to request us to rectify or update any of your personal information that is incomplete or inaccurate. |
| 63 | Information from Third-party Services. | 63 | Right to object or restrict processing : You may have the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest or for direct marketing. |
| 64 | If you choose to link our Services to a third-party account, we may receive information about you, including your username from the third-party product and information regarding your profile and your use of the third-party account. | 64 | We may continue to process your personal information where permitted or required by applicable law. |
| 65 | If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options. | 65 | Right to withdraw your consent : To the extent processing of your personal information is based on your consent, you may withdraw your consent at any time. |
| 66 | Information from Third-party Community-Driven Platforms . | 66 | The lawfulness of our processing before you withdraw your consent will not be affected by such withdrawal. |
| 67 | We collect information from forum-based, real-time communications, and other third-party community-driven platforms relating to opinions and user experiences with respect our products. 2. | 67 | Right to Appeal : If we deny your request, you may have the right to appeal our decision regarding your privacy request. |
| 68 | HOW DO WE USE YOUR PERSONAL INFORMATION? | 68 | Right to lodge a complaint : You have the right to lodge a complaint with your local data protection authority. |
| 69 | In Short: We may use your Personal Information for various purposes We use Personal Information collected via our Services for a variety of business purposes described below. | 69 | You may submit a request to exercise these rights by contacting us at privacy@cognition.ai . |
| 70 | We may use the information we collect or receive: To provide and maintain our Services. | 70 | We will not discriminate against you for exercising any of your rights provided to you under law. |
| 71 | We may use any of the categories of Personal Information described in Section 1 above to provide our Service and troubleshoot technical issues. | 71 | To protect your privacy and security, we may take steps to verify your identity before complying with your request, including to ask for further information, and we may decline your request if we are unable to verify your identity. |
| 72 | To facilitate account creation and logon process. | 72 | Under certain US data privacy laws, you may also designate an authorized agent to make these requests on your behalf. |
| 73 | We use Communications Information to facilitate account creation and logon process for the performance of the contract. | 73 | Before accepting a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. |
| 74 | If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we also use the Information from Third-Party Services and Registration Information for this purpose. | 74 | The above rights are not absolute, and may only apply or be denied in certain circumstances. |
| 75 | To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services. | 75 | How to contact us with questions If you have any questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at privacy@cognition.ai . |
| 76 | We may use your Log and Usage Information and Prompts and Outputs Information for this purpose. | 76 | Changes to this Privacy Policy We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. |
| 77 | To post testimonials. | 77 | We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes or as otherwise required by law. |
| 78 | We post testimonials on our Website that may contain Testimonial Information. | 78 | The date the Privacy Policy was last updated is identified at the top of this page. |
| 79 | Prior to posting such a testimonial, we will obtain your consent to use your name and the content of the testimonial. | 79 | Linkedin X [Twitter] Website Terms of Use Enterprise Terms of Service Platform Terms of Service Privacy Policy Acceptable Use Policy Data Processing Addendum Security |
| 80 | We also post on our Website or social media accounts testimonials collected as Information from Third-party Community-Driven Platforms. | — | Removed |
| 81 | If you wish to update or delete your testimonial, please contact us at privacy@windsurf.com and be sure to include your name, testimonial location, and contact information. | — | Removed |
| 82 | Request feedback. | — | Removed |
| 83 | We may use your Communications Information to request feedback and to contact you about your use of our Website or Services. | — | Removed |
| 84 | To manage user accounts. | — | Removed |
| 85 | We may use your Registration Information, Communications Information, and Information from Third-party Services for the purposes of managing your account and keeping it in working order. | — | Removed |
| 86 | To send administrative information to you. | — | Removed |
| 87 | We may use your Registration Information Communications Information, and Log and Usage Information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. | — | Removed |
| 88 | To protect our Services. | — | Removed |
| 89 | We may use any of the categories of your Personal Information described in Section 1 as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention). | — | Removed |
| 90 | To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract. | — | Removed |
| 91 | We may use any of the categories of your Personal Information described in Section 1 for this purpose. | — | Removed |
| 92 | To respond to legal requests and prevent harm. | — | Removed |
| 93 | If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. | — | Removed |
| 94 | We may use any of the categories of your Personal Information described in Section 1 for this purpose. | — | Removed |
| 95 | To respond to user inquiries/offer support to users. | — | Removed |
| 96 | We may use your Registration Information, Communications Information, Log and Usage Information, Prompts and Outputs Information, and Information from Third-party Services to respond to your inquiries and solve any potential issues you might have with the use of our Services. | — | Removed |
| 97 | To send you marketing and promotional communications. | — | Removed |
| 98 | We and/or our third-party marketing partners may use Registration Information, Communications Information, Log and Usage Information, and Information from Third-party Services for our marketing purposes, if this is in accordance with your marketing preferences. | — | Removed |
| 99 | For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect Personal Information from you. | — | Removed |
| 100 | You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below). | — | Removed |
| 101 | For other business purposes. | — | Removed |
| 102 | We may use your Registration Information, Communications Information, Log and Usage Information, Information from Third-party Services, and Information from Third-party Community-Driven Platforms for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, marketing and your experience. | — | Removed |
| 103 | We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include Personal Information. 3. | — | Removed |
| 104 | LEGAL BASES FOR PROCESSING EUROPEAN PERSONAL INFORMATION If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), we only process your Personal Information when we have a valid “legal basis”, including as set forth below. | — | Removed |
| 105 | Consent. | — | Removed |
| 106 | You have consented to the use of your Personal Information. | — | Removed |
| 107 | Contractual Necessity. | — | Removed |
| 108 | We need your Personal Information to provide you with our Services. | — | Removed |
| 109 | For example, we may need to process your Personal Information to respond to your inquiries or requests, and to otherwise manage and provide our Services. | — | Removed |
| 110 | Compliance with a Legal Obligation. | — | Removed |
| 111 | We may have a legal obligation to use your Personal Information. | — | Removed |
| 112 | For example, we may process your Personal Information to comply with tax, labor and accounting obligations, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). | — | Removed |
| 113 | Legitimate Interests. | — | Removed |
| 114 | We or a third party have a legitimate interest in using your Personal Information. | — | Removed |
| 115 | Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services, to prevent fraud and potential illegal or offensive activities, and to establish, exercise or defend legal claims. | — | Removed |
| 116 | We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests. 4. | — | Removed |
| 117 | WILL YOUR PERSONAL INFORMATION BE DISCLOSED TO ANYONE? | — | Removed |
| 118 | In Short: We only disclose Personal Information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. | — | Removed |
| 119 | More specifically, we may process your data or disclose your personal information in the following situations: Partners and Affiliates . | — | Removed |
| 120 | We may disclose any categories of Personal Information described in Section 1 above to our current or future partners and affiliates for any of the purposes described in this Privacy Policy. | — | Removed |
| 121 | Business Transfers. | — | Removed |
| 122 | We may disclose or transfer any categories of Personal Information described in Section 1 above in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. | — | Removed |
| 123 | Vendors, Consultants and Other Third-Party Service Providers. | — | Removed |
| 124 | We may disclose any categories of Personal Information described in Section 1 above with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. | — | Removed |
| 125 | For more information, see “TO WHOM WILL YOUR PERSONAL INFORMATION BE DISCLOSED?” below. | — | Removed |
| 126 | We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. | — | Removed |
| 127 | This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. | — | Removed |
| 128 | Unless described in this notice, we do not disclose, sell, rent or trade any of your information with third parties for their promotional purposes. | — | Removed |
| 129 | Third-Party App Integrations. | — | Removed |
| 130 | If you connect a third-party application to our Services, we may disclose your Registration Information to that third party. | — | Removed |
| 131 | Analytics Partners . | — | Removed |
| 132 | We use analytics services such as Google Analytics to collect and process certain analytics data. | — | Removed |
| 133 | These services may also collect information about your use of other websites, apps, and online resources. | — | Removed |
| 134 | You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/ . | — | Removed |
| 135 | We may disclose Log and Usage Data to these providers. | — | Removed |
| 136 | As Required By Law and Similar Disclosures . | — | Removed |
| 137 | We may access, preserve, and disclose any categories of Personal Information described in Section 1 if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order or subpoena, respond to your requests, or protect your, our, or others’ rights, property, or safety. | — | Removed |
| 138 | Consent . | — | Removed |
| 139 | We may also disclose any categories of Personal Information described in Section 1 with your permission. | — | Removed |
| 140 | Your employer or related organization - If you create an account using an email address belonging or relating to your employer or another organization, we may share the fact that you have an account and certain Registration Information (such as your email address) with your employer or organization to, for example, enable you to be added to their business or enterprise account. | — | Removed |
| 141 | In addition, administrators of any enterprise or business account may be able to access certain information associated with your account, including your Prompts and Output Information, and be able to control your account and such information. 5. | — | Removed |
| 142 | TO WHOM WILL YOUR PERSONAL INFORMATION BE DISCLOSED? | — | Removed |
| 143 | In Short: We only disclose Personal Information to the following categories of third parties. | — | Removed |
| 144 | We only disclose your Personal Information to the following categories of third parties. | — | Removed |
| 145 | If we have disclosed your Personal Information based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?". | — | Removed |
| 146 | Website Hosting Service Providers Cloud Computing Services Customer Intelligence Platforms 6. | — | Removed |
| 147 | DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? | — | Removed |
| 148 | In Short: We may use cookies and other tracking technologies to collect and store your information. | — | Removed |
| 149 | We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store Personal Information, including your browser type, operating system version, domains, IP address, the URL of the page that referred you, referring/exit pages and information about your interactions with our Website (such as the time of your visit to our Website, page views, where you have clicked and Website traffic trends). | — | Removed |
| 150 | To learn more about cookies, please visit www.allaboutcookies.org/ . | — | Removed |
| 151 | We and our third-party partners collect information using cookies, pixel tags, or similar technologies. | — | Removed |
| 152 | Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. | — | Removed |
| 153 | Cookies are small text files containing a string of alphanumeric characters. | — | Removed |
| 154 | We may use both session cookies and persistent cookies. | — | Removed |
| 155 | A session cookie disappears after you close your browser. | — | Removed |
| 156 | A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. | — | Removed |
| 157 | Cookies can be used for performance management or collecting information on how our Services are being used for analytics purposes. | — | Removed |
| 158 | They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. | — | Removed |
| 159 | We may also use pixel tags and web beacons on our Services. | — | Removed |
| 160 | These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. | — | Removed |
| 161 | Below is an overview of the types of cookies we and third parties may use to collect Personal Information. | — | Removed |
| 162 | Strictly Necessary Cookies. | — | Removed |
| 163 | Some cookies are strictly necessary to make our Services available to you. | — | Removed |
| 164 | We cannot provide you with our Services without this type of cookies. | — | Removed |
| 165 | Functional Cookies. | — | Removed |
| 166 | Functional cookies are used to recognize you when you return to our Services. | — | Removed |
| 167 | This enables us to adapt our content for you and remember your preferences. | — | Removed |
| 168 | Analytical or Advertising Cookies. | — | Removed |
| 169 | Analytical or advertising cookies can be used for website analytics purposes in order to operate, maintain and improve our Services, and to promote our Services. | — | Removed |
| 170 | Please review your web browser’s “Help” file to learn how you may modify your cookie settings. | — | Removed |
| 171 | Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential. 7. | — | Removed |
| 172 | IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY? | — | Removed |
| 173 | In Short: We may transfer, store, and process your Personal Information in countries other than your own. | — | Removed |
| 174 | Our servers are located in the United States. | — | Removed |
| 175 | If you are accessing our Services from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed by us in our facilities and by those third parties to whom we may disclose your Personal Information (see "WILL YOUR INFORMATION BE DISCLOSED TO ANYONE?" above) in the United States, and other countries. | — | Removed |
| 176 | If you are a resident in the EEA, Switzerland or the UK, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. | — | Removed |
| 177 | We may transfer Personal Information from the EEA, Switzerland or the UK to the U.S. and other third countries based on approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. | — | Removed |
| 178 | We may also transfer Personal Information data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. | — | Removed |
| 179 | For more information about the tools that we use to transfer Personal Information, or to request a copy of the safeguards that we use, you can contact us as described below. 8. | — | Removed |
| 180 | HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION? | — | Removed |
| 181 | In Short: We keep your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law. | — | Removed |
| 182 | We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). | — | Removed |
| 183 | When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. 9. | — | Removed |
| 184 | THIRD PARTIES Our Services may contain links to other websites, products, or services that we do not own or operate. | — | Removed |
| 185 | We are not responsible for the privacy practices of these third parties. | — | Removed |
| 186 | Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. | — | Removed |
| 187 | We encourage you to read their privacy policies before providing any Personal Information to them. 10. | — | Removed |
| 188 | HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE? | — | Removed |
| 189 | In Short: We aim to protect your Personal Information through a system of organizational and technical security measures. | — | Removed |
| 190 | We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we process. | — | Removed |
| 191 | However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. | — | Removed |
| 192 | Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Services is at your own risk. | — | Removed |
| 193 | You should only access the Services within a secure environment. 11. | — | Removed |
| 194 | DO WE COLLECT PERSONAL INFORMATION FROM MINORS? | — | Removed |
| 195 | In Short: We do not knowingly collect data from or market to children under 18 years of age. | — | Removed |
| 196 | We do not knowingly solicit data from or market to children under 18 years of age. | — | Removed |
| 197 | By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. | — | Removed |
| 198 | If you become aware of any Personal Information we may have collected from children under age 18, please contact us at privacy@windsurf.com . 12. | — | Removed |
| 199 | WHAT ARE YOUR PRIVACY RIGHTS? | — | Removed |
| 200 | In Short: In some regions, such as the United States, the European Economic Area (EEA), and United Kingdom (UK), you have rights that allow you greater access to and control over your Personal Information. | — | Removed |
| 201 | You may review, change, or terminate your account at any time. | — | Removed |
| 202 | In some regions (like the U.S., the EEA, Switzerland and the UK), you have certain rights under applicable data protection laws. | — | Removed |
| 203 | Your U.S. State Privacy Rights Some U.S. states provide consumers certain rights regarding their Personal Information. | — | Removed |
| 204 | Depending on where you live and subject to certain exceptions, you may exercise the following rights: The right to confirm whether we process your Personal Information and access Personal Information, including the right to obtain a copy of your Personal Information provided by you to us in a portable and readily usable format. | — | Removed |
| 205 | The right to correct inaccurate Personal Information that we maintain about you. | — | Removed |
| 206 | The right to delete Personal Information about or concerning you. | — | Removed |
| 207 | The right to opt out of the “sale” of your Personal Information and the processing of your Personal Information for targeted advertising. | — | Removed |
| 208 | The right to be free from discriminatory treatment for the exercise of your privacy rights. | — | Removed |
| 209 | The right to appeal any decision with regard to your privacy request. | — | Removed |
| 210 | The right to opt out of profiling in furtherance of producing legal or significant decisions concerning a consumer. | — | Removed |
| 211 | We do not engage in such profiling. | — | Removed |
| 212 | Submitting Requests . | — | Removed |
| 213 | You can submit access, correction, deletion, and appeal requests by sending us an email to data-subject-request@windsurf.com . | — | Removed |
| 214 | Verification. | — | Removed |
| 215 | Requests for access to, deletion, or correction of Personal Information are subject to our ability to verify your identity. | — | Removed |
| 216 | If you have a Windsurf account, we will verify your identity by asking you to log into your account. | — | Removed |
| 217 | If you do not have an account, we will attempt to verify your identity by asking for information that we may have about you, such as your name, email address, and other information. | — | Removed |
| 218 | Authorizing an Agent . | — | Removed |
| 219 | If you are acting as an authorized agent on behalf of another consumer, please send an email to data-subject-request@windsurf.com and attach a written authorization signed by the resident. | — | Removed |
| 220 | Depending on the nature of the request, we may still require the consumer to directly verify their identity and confirm that they have provided you permission to submit the request. | — | Removed |
| 221 | Your EEA, Switzerland, and the UK Privacy Rights These privacy rights may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. | — | Removed |
| 222 | In certain circumstances, you may also have the right to object to the processing of your personal information. | — | Removed |
| 223 | To make such a request, please use the contact details provided below. | — | Removed |
| 224 | We will consider and act upon any request in accordance with applicable data protection laws. | — | Removed |
| 225 | Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. | — | Removed |
| 226 | Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. | — | Removed |
| 227 | If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time and free of charge. | — | Removed |
| 228 | Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. | — | Removed |
| 229 | If you are a resident in the EEA or UK and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. | — | Removed |
| 230 | You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm . | — | Removed |
| 231 | If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html . | — | Removed |
| 232 | If you have questions or comments about your privacy rights, you may email us at data-subject-request@windsurf.com . | — | Removed |
| 233 | Account Information If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account. | — | Removed |
| 234 | Contact us using the contact information provided. | — | Removed |
| 235 | Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. | — | Removed |
| 236 | However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Service and/or comply with applicable legal requirements. | — | Removed |
| 237 | Cookies and similar technologies: technologies: Most Web browsers are set to accept cookies by default. | — | Removed |
| 238 | If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. | — | Removed |
| 239 | If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. | — | Removed |
| 240 | To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/ . | — | Removed |
| 241 | Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. | — | Removed |
| 242 | You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. | — | Removed |
| 243 | To otherwise opt-out, you may: Contact us using the contact information provided. 13. | — | Removed |
| 244 | CONTROLS FOR DO-NOT-TRACK FEATURES Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. | — | Removed |
| 245 | At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. | — | Removed |
| 246 | As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. | — | Removed |
| 247 | If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. 14. | — | Removed |
| 248 | DO WE MAKE UPDATES TO THIS NOTICE? | — | Removed |
| 249 | In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. | — | Removed |
| 250 | We may update this Privacy Policy from time to time. | — | Removed |
| 251 | The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. | — | Removed |
| 252 | If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. | — | Removed |
| 253 | We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. 15. | — | Removed |
| 254 | HOW CAN YOU CONTACT US ABOUT THIS NOTICE? | — | Removed |
| 255 | Exafunction, Inc. is responsible and the data controller for processing your Personal Information. | — | Removed |
| 256 | If you have questions or comments about this notice, you may email us at privacy@windsurf.com or by post to: Exafunction, Inc. 990 Villa St. Mountain View, CA 94041 United States 16. | — | Removed |
| 257 | HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? | — | Removed |
| 258 | Based on the applicable laws of your country, you may have the right to request access to the Personal Information we collect from you, change that information, or delete it in some circumstances. | — | Removed |
| 259 | To request to review, update, or delete your Personal Information, please visit: windsurf.com/contact. | — | Removed |
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