Windsurf · Windsurf Privacy Policy · View original document ↗

International Data Transfers via Standard Contractual Clauses

Medium severity Medium confidence Explicitdocumentlanguage Uncommon · 12 of 343 platforms
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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)

The clause establishes the operational framework for cross-border data flows and acknowledges that destination jurisdictions may have less comprehensive data protection regimes than the EEA, Switzerland, or UK. It specifies the contractual mechanism—Standard Contractual Clauses—that governs the lawfulness of these international transfers under GDPR and equivalent regimes.

Interpretive note: The policy does not specify whether Transfer Impact Assessments have been conducted, whether the EU-U.S. Data Privacy Framework is relied upon, or which specific third countries beyond the U.S. may receive transferred data, leaving the full scope of transfer mechanisms uncertain.

Consumer impact (what this means for users)

Users from the EEA, Switzerland, and UK are notified that their personal information will be transferred to and processed in the United States and other countries, with protections structured through Standard Contractual Clauses rather than adequacy decisions. The terms operate on the basis that users accessing the service consent to this cross-border processing upon continued use.

How other platforms handle this

DocuSign Medium

When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to other countries that have not been found to provide an adequate level of data protection, we use legal mechanisms such as Standard Contractual Clauses approved by the European Commission to h...

Peloton Medium

Your personal information may be transferred to, processed and stored in countries other than the country in which you are resident, including the United States, Australia, Canada, the European Union and the UK. We take appropriate safeguards to protect your personal information in accordance with t...

Fiverr Medium

Your personal information may be transferred to and processed in countries outside your country of residence, including the United States and Israel, which may have data protection laws that differ from those in your country. We rely on appropriate safeguards, such as standard contractual clauses ap...

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▸ View Original Clause Language DOCUMENT RECORD
"
Our servers are located in the United States. 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. 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. 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.

— Excerpt from Windsurf's Windsurf Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Windsurf Privacy Policy
Entity
Windsurf
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 12, 2026
Record ID
CA-P-008828
Document ID
CA-D-00486
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
ca691298a1c366388f0a1f48ecc65849f0a7d07d6de5b840c646e62cf6239715
Analysis generated
April 30, 2026 05:21 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Windsurf
Document: Windsurf Privacy Policy
Record ID: CA-P-008828
Captured: 2026-04-30 05:21:09 UTC
SHA-256: ca691298a1c36638…
URL: https://conductatlas.com/platform/windsurf/windsurf-privacy-policy/international-data-transfers-via-standard-contractual-clauses/
Accessed: June 30, 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 International Data Transfers via Standard Contractual Clauses clause do?

The clause establishes the operational framework for cross-border data flows and acknowledges that destination jurisdictions may have less comprehensive data protection regimes than the EEA, Switzerland, or UK. It specifies the contractual mechanism—Standard Contractual Clauses—that governs the lawfulness of these international transfers under GDPR and equivalent regimes.

How does this clause affect you?

Users from the EEA, Switzerland, and UK are notified that their personal information will be transferred to and processed in the United States and other countries, with protections structured through Standard Contractual Clauses rather than adequacy decisions. The terms operate on the basis that users accessing the service consent to this cross-border processing upon continued use.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 12 platforms. See the full comparison.

Is ConductAtlas affiliated with Windsurf?

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