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

Real-Time and Ahead-of-Time Personalization Data Collection

Low severity High confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

The document discloses that Windsurf makes background requests to its servers without user-triggered input events, for the purposes of building context, understanding developer intent, and scanning for potential next steps. Embedding computation requests are also made proactively to process existing codebases.

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 data transmission to Windsurf servers occurs continuously during IDE use, not only in response to explicit user actions. Compliance teams assessing network traffic, data minimization, and consent requirements should account for this continuous background data transmission in their assessments.

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 these terms, the Windsurf client makes background requests to servers during IDE use independent of user keystrokes or prompts, transmitting context data for personalization and intent modeling purposes. The document states that individual code snippets rather than entire codebases are transmitted even for codebase-level operations, and that usage metadata rather than code data is logged to analytics infrastructure.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

To stop us collecting your location information, you can update your device settings, stop using the Service, or uninstall our mobile apps.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Real-time Personalization: Even without a trigger such as a keystroke or user prompt input, requests are made in the background to build context, understand developer intent, or scan for potential next steps. Ahead-of-time Personalization: To build state on the existing codebases and other data sources, requests are made to perform embedding computations.

Excerpt from Windsurf's Security & Data Handling

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

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 →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
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 Security & Data Handling
Entity
Windsurf
Document last updated
May 11, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013138
Document ID
CA-D-00783
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
09f15224ef746c31f64489deed565c66e77ca519b3c55d45f54937824fef52f0
Analysis generated
May 21, 2026 05:27 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Windsurf
Document: Windsurf Security & Data Handling
Record ID: CA-P-013138
Captured: 2026-05-21 05:27:25 UTC
SHA-256: 09f15224ef746c31…
URL: https://conductatlas.com/platform/windsurf/windsurf-security-data-handling/provision/CA-P-013138/real-time-and-ahead-of-time-personalization-data-collection/
Accessed: Sept. 15, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does Windsurf's Real-Time and Ahead-of-Time Personalization Data Collection clause do?

This provision establishes that data transmission to Windsurf servers occurs continuously during IDE use, not only in response to explicit user actions. Compliance teams assessing network traffic, data minimization, and consent requirements should account for this continuous background data transmission in their assessments.

How does this clause affect you?

Under these terms, the Windsurf client makes background requests to servers during IDE use independent of user keystrokes or prompts, transmitting context data for personalization and intent modeling purposes. The document states that individual code snippets rather than entire codebases are transmitted even for codebase-level operations, and that usage metadata rather than code data is logged to analytics infrastructure.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 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.