Windsurf may share any category of personal information it collects with current or future business partners and affiliated companies for any of the purposes listed in the policy.
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
The provision authorizes disclosure of all described categories of personal information, including Prompts and Outputs Information and Log and Usage Information, to an open-ended set of current or future partners and affiliates, without specifying which entities qualify as affiliates or the limitations on their use.
Interpretive note: The scope of 'current or future partners and affiliates' is not defined in the document, creating ambiguity about which entities qualify and what data use obligations apply to them.
The policy permits disclosure of any personal information category, including user-submitted prompts and usage activity, to current or future partners and affiliates; the set of qualifying entities and their data use obligations are not defined within this provision.
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"Partners and Affiliates. 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.— Excerpt from Windsurf's Windsurf Privacy Policy
REGULATORY LANDSCAPE: This provision engages GDPR Articles 13 and 14, which require identification of recipients or categories of recipients at the time of data collection. CCPA and CPRA require disclosure of categories of third parties with whom personal information is shared. The broad scope of this clause, covering all personal information categories and an undefined set of future affiliates, may require evaluation under these transparency requirements. GOVERNANCE EXPOSURE: Medium. The use of 'current or future partners and affiliates' without further definition creates ambiguity about the universe of entities that may receive personal data. For GDPR purposes, the absence of a defined list of affiliates or adequate description of safeguards for affiliate transfers may create a gap in required transparency disclosures. JURISDICTION FLAGS: EEA and UK users face exposure where affiliate disclosures involve cross-border transfers without documented transfer mechanisms. California residents have a right under CPRA to know categories of third parties with whom data is shared; the broad affiliate definition may complicate compliance with this right. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers entering into DPAs with Windsurf should confirm whether affiliate disclosures are restricted or governed by the processor agreement, or whether data processed on behalf of the enterprise customer remains outside the scope of the affiliate disclosure provision. COMPLIANCE CONSIDERATIONS: Legal teams should request a list of current affiliates and clarify the criteria by which future affiliates are defined. Data mapping should reflect the possibility of affiliate disclosures for all personal data categories.
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The provision authorizes disclosure of all described categories of personal information, including Prompts and Outputs Information and Log and Usage Information, to an open-ended set of current or future partners and affiliates, without specifying which entities qualify as affiliates or the limitations on their use.
The policy permits disclosure of any personal information category, including user-submitted prompts and usage activity, to current or future partners and affiliates; the set of qualifying entities and their data use obligations are not defined within this provision.
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