Windsurf · Windsurf Privacy Policy · View original document ↗

Prompts and Outputs as Personal Information

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
Share 𝕏 Share in Share 🔒 PDF
Monitor governance changes for Windsurf Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
Document Record

What it is

Windsurf collects and retains the text you type into its AI tool and the responses the AI generates; the policy acknowledges this content may qualify as personal information depending on how it is linked to your account.

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 establishes that user-submitted Prompts and AI-generated Outputs are collected and retained, and that they may constitute personal information, which has implications for data subject rights, retention, and the AI training use also described in the policy.

Interpretive note: The conditional framing ('depending on how it is associated with your account') creates ambiguity about when Prompts and Outputs are treated as personal information subject to data subject rights.

Consumer impact (what this means for users)

The policy states that all text entered as prompts and all AI-generated outputs are collected and retained, and may qualify as personal information; users who enter sensitive, personal, or proprietary content into Windsurf should be aware that this content is subject to the full scope of the policy's data use provisions including AI training.

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
    Email privacy@windsurf.com to request deletion of your Prompts and Outputs Information and any other personal data associated with your account.

How other platforms handle this

Anthropic Medium

As between you and Anthropic, and to the extent permitted by applicable law, you retain any right, title, and interest that you have in the Inputs you submit. Subject to your compliance with our Terms, we assign to you all of our right, title, and interest—if any—in Outputs.

Supabase Medium

After registration, you may create, upload or transmit files, documents, videos, images, data or information as part of your use of the Service (collectively, "User Content"). This includes any inputs you provide to our AI-powered support tools and outputs generated in response to your inputs. User ...

Klarna Medium

We use your personal data to develop, train, and improve our artificial intelligence and machine learning models. This includes using your transaction data, behavioral data, and interaction data to enhance our fraud detection, credit assessment, and personalization capabilities. We take steps to pro...

See all platforms with this clause type →

Monitoring

Windsurf has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.

Start Watcher free trial Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
Our Services allow you to submit text to the Services ("Prompts"), which generate responses based on your Prompts ("Outputs"). We will collect any information you choose to provide in your Prompts and this information may be reproduced in the Outputs. 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.

— Excerpt from Windsurf's Windsurf Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The characterization of Prompts and Outputs as potential personal information engages GDPR Article 4 definitions, CCPA Section 1798.140 definitions, and equivalent definitions under other state comprehensive privacy laws. The conditional framing ('may constitute or contain Personal Information, depending on how it is associated') creates ambiguity about when these data categories are subject to data subject rights and deletion obligations. GOVERNANCE EXPOSURE: Medium. The conditional qualification on whether Prompts and Outputs constitute personal information may create inconsistent application of data subject rights requests. If a user requests deletion of their data, the question of whether their Prompts and Outputs are treated as personal information (and therefore subject to the deletion request) may depend on internal data linkage practices not disclosed in the policy. JURISDICTION FLAGS: California residents with rights to deletion and opt-out of certain processing under CPRA should note the conditional framing. EEA and UK users' rights of access, erasure, and portability under GDPR may apply to Prompts and Outputs where they are linked to identifiable accounts. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should confirm in their DPA how Windsurf treats Prompts and Outputs in response to data subject access and deletion requests, and whether the conditional personal information framing affects the scope of processor obligations. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the conditional personal information classification is consistent with applicable law definitions, which may treat linked account data as personal information regardless of how the company chooses to classify it. Deletion request workflows should be reviewed to ensure Prompts and Outputs are addressed.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

Track 1 platform — free Try Watcher free for 14 days

Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.

Applicable agencies

  • FTC
    The FTC has jurisdiction over deceptive practices related to consumer data disclosures, including whether conditional personal information classifications are consistent with consumer-facing privacy representations.
    File a complaint →

Applicable regulations

EU AI Act
European Union
California AB 2013 AI Training Data Transparency
US-CA
Colorado AI Act
US-CO
EU AI Act - High Risk Provisions
EU
GDPR
European Union
Texas AI Act
Texas, USA
Trump Executive Order on AI Policy Framework
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-011520
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-011520
Captured: 2026-04-30 05:21:09 UTC
SHA-256: ca691298a1c36638…
URL: https://conductatlas.com/platform/windsurf/windsurf-privacy-policy/prompts-and-outputs-as-personal-information/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Related Analysis

Professional Governance Intelligence

Need to monitor specific governance provisions?

Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Professional free trial

Or start with Watcher →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Windsurf's Prompts and Outputs as Personal Information clause do?

This provision establishes that user-submitted Prompts and AI-generated Outputs are collected and retained, and that they may constitute personal information, which has implications for data subject rights, retention, and the AI training use also described in the policy.

How does this clause affect you?

The policy states that all text entered as prompts and all AI-generated outputs are collected and retained, and may qualify as personal information; users who enter sensitive, personal, or proprietary content into Windsurf should be aware that this content is subject to the full scope of the policy's data use provisions including AI training.

Is ConductAtlas affiliated with Windsurf?

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