In the event of a merger, acquisition, or sale, Windsurf may transfer all categories of personal information it holds to the acquiring or merging company, including during the negotiation phase before any transaction is completed.
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 personal data transfer during merger or acquisition negotiations, meaning data may move to a third party before a transaction is finalized, and users are not guaranteed notice or an opt-out in connection with such a transfer.
All categories of personal information collected by Windsurf, including Prompts and Outputs, may be transferred to an acquiring company during negotiations or upon completion of a merger or acquisition under this provision.
How other platforms handle this
We may disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
By issuing a chargeback or refund request for Premium subscriptions paid for through a third party, you agree to allow Telegram to release necessary data to that third party regarding your account status and Telegram Premium purchases.
We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, or dissolution, transaction, or proceeding involving all or a portion of our business.
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"Business Transfers. 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.— Excerpt from Windsurf's Windsurf Privacy Policy
REGULATORY LANDSCAPE: Business transfer provisions are common in privacy policies and engage GDPR Article 6 legitimate interests as a potential legal basis for transfers in the context of corporate transactions. CCPA and CPRA require disclosure of business transfer data sharing in privacy notices. The FTC has addressed business transfer clauses in the context of material changes to privacy practices. GOVERNANCE EXPOSURE: Medium. The inclusion of 'during negotiations' as a trigger for potential data disclosure is notable; data transferred during negotiations may be subject to the acquirer's privacy practices before a transaction is complete and before users are notified. This may require evaluation under GDPR's purpose limitation principle. JURISDICTION FLAGS: EEA and UK users' data transferred during corporate transactions would still be subject to GDPR and UK GDPR, requiring the acquiring entity to establish its own legal basis for processing. California residents should note that CPRA includes provisions related to data transfers in business transactions. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should assess whether their DPAs with Windsurf include change of control provisions, successor entity obligations, or data return and deletion rights in the event of an acquisition. COMPLIANCE CONSIDERATIONS: Legal teams should monitor for material changes to the policy or notifications of corporate transactions that may trigger data transfer obligations. The policy does not describe a user notification mechanism for business transfers.
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The provision authorizes personal data transfer during merger or acquisition negotiations, meaning data may move to a third party before a transaction is finalized, and users are not guaranteed notice or an opt-out in connection with such a transfer.
All categories of personal information collected by Windsurf, including Prompts and Outputs, may be transferred to an acquiring company during negotiations or upon completion of a merger or acquisition under this provision.
ConductAtlas has identified this type of provision across 8 platforms. See the full comparison.
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