Provision record
Windsurf · Windsurf Security & Data Handling · View original document ↗

Default Model Training Data Use

Medium severity High confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The document states that user data is used for model training by default, with a self-service opt-out available to paid plan users through the Data Controls settings page; on the Teams plan, only administrators may exercise this opt-out.

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 a default opt-in structure for model training across non-enterprise paid tiers, requiring affirmative action by the user or administrator to disable. The tiered access to the opt-out mechanism (individual paid users versus Teams administrators) creates a differentiated data governance structure that organizations must account for in their internal access and consent workflows.

Recent Activity

This document changed recently

High Jul 6, 2026

The updated terms establish a default policy permitting Windsurf to use customer data for model training purposes to improve services. Previously, the company required explicit opt-in before any training use. Under the revised policy, data training occurs automatically for free and paid users unless they affirmatively opt out through the Data Controls settings page. Once disabled, the terms state your data will not be used for training and Zero Data Retention will be enabled with model providers. Enterprise customers operate under a different standard, requiring express prior written consent before any training use occurs.

View change record →
Medium Jun 23, 2026

The updated document establishes explicit commitments about how Windsurf protects data and manages security. The terms state that all data transmission is encrypted in transit and at rest, that access to production systems is restricted to a small number of employees or contractors based on business roles, and that production systems are monitored via logging, error handling, and monitoring dashboards. The document discloses that Windsurf obtained SOC 2 Type II certification as of March 2024 and that all employees and contractors are required to use multi-factor authentication and receive annual security training. These disclosures describe organizational practices rather than establishing new user-facing rights or obligations.

View change record →

Consumer impact (what this means for users)

Under this provision, user data is processed for model training unless the user (or, on the Teams plan, an administrator) affirmatively opts out via the Data Controls settings page. The agreement states that after opt-out, Zero Data Retention will be enabled with Cognition's model providers.

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.
  • Opt Out of Arbitration
    Log in to your Devin account, navigate to the Data Controls settings page, and enable the opt-out from model training data use. On the Teams plan, this action must be completed by an account administrator.

Cross-platform context

See how other platforms handle Default Model Training Data Use and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
By default, we may use your data for model training purposes to improve and enhance the Services. If you're on a paid plan, you can opt out at any time on the Data Controls settings page. After you opt out, your data will not be used for training and Zero Data Retention will be enabled with our model providers. On the Teams plan, only an administrator can exercise the opt-out.

Excerpt from Windsurf's Security & Data Handling

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: The default opt-in model training provision engages GDPR Article 6 lawful basis requirements and the data minimization principle, as well as CCPA/CPRA opt-out rights for California residents.

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 Security & Data Handling
Entity
Windsurf
Document last updated
May 11, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015178
Document ID
CA-D-00783
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
87e0c922df6f81ddd3b0b0cd1a4c89e032f31245c90a31c47bfc8fc12173717b
Analysis generated
July 9, 2026 07:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Windsurf
Document: Windsurf Security & Data Handling
Record ID: CA-P-015178
Captured: 2026-07-09 07:22:40 UTC
SHA-256: 87e0c922df6f81dd…
URL: https://conductatlas.com/platform/windsurf/windsurf-security-data-handling/provision/CA-P-015178/default-model-training-data-use/
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 Default Model Training Data Use clause do?

This provision establishes a default opt-in structure for model training across non-enterprise paid tiers, requiring affirmative action by the user or administrator to disable. The tiered access to the opt-out mechanism (individual paid users versus Teams administrators) creates a differentiated data governance structure that organizations must account for in their internal access and consent workflows.

How does this clause affect you?

Under this provision, user data is processed for model training unless the user (or, on the Teams plan, an administrator) affirmatively opts out via the Data Controls settings page. The agreement states that after opt-out, Zero Data Retention will be enabled with Cognition's model providers.

Is ConductAtlas affiliated with Windsurf?

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