Provision record
Windsurf · Windsurf Privacy Policy · View original document ↗

Asset Transfer and Acquisition Data Sharing

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Document Record

What it is

The policy states that user personal information may be shared during the evaluation of and entry into asset sales, acquisitions, mergers, or other change of control events, including bankruptcy proceedings, without a requirement for separate user consent.

This analysis describes what Windsurf'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision asserts that personal information across all stated categories may be transferred to third parties in connection with corporate transactions, including during the due diligence evaluation phase. This applies to the full scope of user data described in the policy, including user content, account information, and usage data.

Consumer impact (what this means for users)

Under this clause, personal information including user content and account data may be transferred to potential or actual acquirers in connection with a merger, acquisition, asset sale, or bankruptcy proceeding. The policy does not specify a consent mechanism or advance notice requirement for such transfers.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Submit a data deletion request to privacy@cognition.ai if you wish to request erasure of your personal information prior to any corporate transaction. Identity verification may be required before the request is processed.

Cross-platform context

See how other platforms handle Asset Transfer and Acquisition Data Sharing and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
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. 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.

Excerpt from Windsurf's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Windsurf Privacy Policy
Entity
Windsurf
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015492
Document ID
CA-D-00486
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8ae03e5811c24ed5bbaea9f9c76490240433de69cd8dd9fe5ba748fe87ea971b
Analysis generated
July 9, 2026 08:07 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Windsurf
Document: Windsurf Privacy Policy
Record ID: CA-P-015492
Captured: 2026-07-09 08:07:32 UTC
SHA-256: 8ae03e5811c24ed5…
URL: https://conductatlas.com/platform/windsurf/windsurf-privacy-policy/provision/CA-P-015492/asset-transfer-and-acquisition-data-sharing/
Accessed: Sept. 15, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Windsurf's Asset Transfer and Acquisition Data Sharing clause do?

This provision asserts that personal information across all stated categories may be transferred to third parties in connection with corporate transactions, including during the due diligence evaluation phase. This applies to the full scope of user data described in the policy, including user content, account information, and usage data.

How does this clause affect you?

Under this clause, personal information including user content and account data may be transferred to potential or actual acquirers in connection with a merger, acquisition, asset sale, or bankruptcy proceeding. The policy does not specify a consent mechanism or advance notice requirement for such transfers.

Is ConductAtlas affiliated with Windsurf?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Windsurf.