Windsurf · Windsurf Terms of Service · View original document ↗

Third-Party Platform Data Sharing

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Windsurf recorded 7 documented changes in the last 30 days.
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Document Record

What it is

If you connect Windsurf to third-party tools like IDEs, web search, or MCP servers, your code and content may be shared with those third parties, and Windsurf takes no responsibility for how those third parties handle your data.

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 agreement permits User Content to flow to third-party platforms upon integration, with Exafunction disclaiming all liability for how those platforms use the data, meaning users' code and content are subject to the third party's own terms once shared.

Recent Activity

This document changed recently

Medium Jul 1, 2026

The updated terms indicate that Windsurf is now operating as the Cognition Platform under Cognition AI, Inc., replacing the prior Exafunction, Inc. structure. The revised terms state that prior terms continue to govern use for 30 days from the posting date (July 1, 2026), and that continued access after that period constitutes acceptance of the updated terms. Users who do not agree with the new terms are instructed to stop using or accessing the Services. The specific substantive changes to user rights, data collection, fees, or service functionality are not detailed in the provided change summary.

View change record →

Consumer impact (what this means for users)

Enabling third-party integrations with Windsurf authorizes the exchange of User Content with those platforms. The agreement disclaims Windsurf's liability for the security, use, or handling of that data by third-party providers, placing responsibility on the user to review those providers' terms independently.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Skillshare Medium

We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...

Bumble Medium

We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
You may elect to use or integrate platforms, add-ons, services, or products not provided by Exafunction ("Third-Party Platforms") (e.g. User IDE's, Web Search, MCP Servers) subject to your agreement with the relevant provider and not this Agreement. We do not control nor shall we have liability for such integrations, including their security, functionality, operation, availability, or interoperability with the Service or how they or their providers use User Content. By enabling a Third-Party Platform to interact with the Service, you permit the Service to exchange User Content with such Third-Party Platform.

— Excerpt from Windsurf's Windsurf Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: GDPR's data controller and processor relationship framework may apply to third-party platform integrations, requiring organizations to conduct transfer impact assessments and ensure adequate data protection agreements with those third parties. CCPA's disclosure requirements for data sharing with third parties may also engage. The disclaimer of liability for third-party platforms does not relieve organizations of their own regulatory obligations regarding data transferred to those platforms. (2) GOVERNANCE EXPOSURE: Medium to High for enterprise users. The broad disclaimer of liability for third-party platforms and the automatic permission to exchange User Content upon integration creates data governance complexity, particularly for organizations with sensitive code repositories. (3) JURISDICTION FLAGS: EU users and organizations must evaluate whether third-party platform integrations involve transfers of personal data to third countries and whether adequate safeguards are in place. Healthcare and financial services organizations face heightened exposure due to regulatory requirements governing data sharing with third parties. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should maintain an inventory of all third-party platform integrations enabled by developers and assess each provider's terms, security posture, and data handling practices independently. Vendor assessments should not rely on Windsurf's terms as covering third-party platform data handling. (5) COMPLIANCE CONSIDERATIONS: Legal teams should implement acceptable use policies that specify which third-party integrations are permitted for organizational use of Windsurf, and conduct due diligence on each approved integration's data handling practices.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over disclosure of data sharing practices with third parties and the adequacy of consumer notice regarding how data is handled by integrated third-party services
    File a complaint →

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 Terms of Service
Entity
Windsurf
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 12, 2026
Record ID
CA-P-011647
Document ID
CA-D-00487
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
00ec2ae906a7a237f79cd586583ef2cf26f4725d380b3677eb3b6e7fd4d293ef
Analysis generated
April 30, 2026 05:54 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Windsurf
Document: Windsurf Terms of Service
Record ID: CA-P-011647
Captured: 2026-04-30 05:54:22 UTC
SHA-256: 00ec2ae906a7a237…
URL: https://conductatlas.com/platform/windsurf/windsurf-terms-of-service/third-party-platform-data-sharing/
Accessed: July 4, 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 Third-Party Platform Data Sharing clause do?

The agreement permits User Content to flow to third-party platforms upon integration, with Exafunction disclaiming all liability for how those platforms use the data, meaning users' code and content are subject to the third party's own terms once shared.

How does this clause affect you?

Enabling third-party integrations with Windsurf authorizes the exchange of User Content with those platforms. The agreement disclaims Windsurf's liability for the security, use, or handling of that data by third-party providers, placing responsibility on the user to review those providers' terms independently.

Is ConductAtlas affiliated with Windsurf?

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