Windsurf (Codeium)

Data-handling profile

Trains on input

No — does not train on customer inputs

Retention

Stated policy of 'no training on non-permissive data' — does not train shared models on private customer code. Zero-data-retention is default on team/enterprise plans; code not stored in logs or used for training unless optional features (remote indexing, memories) are explicitly enabled. Self-hosted/on-prem/VPC deployment available (FedRAMP High, HIPAA, BAA supported).

Data region

US

Certifications

none listed

DPA available

Yes

Breach history

Included in a 2025 third-party research report ('Forked and Forgotten') on ~94 unpatched Chromium-derived vulnerabilities affecting Cursor and Windsurf's Electron/Chromium base, exposing an estimated 1.8M developers; vendor-side data-training breach not identified.

EU AI Act

Strong enterprise data-isolation and on-prem deployment options support EU AI Act data-governance requirements for sensitive codebases.

Sources

• https://windsurf.com/privacy-policy
• https://windsurf.com/security
• https://www.ox.security/blog/94-vulnerabilities-in-cursor-and-windsurf-put-1-8m-developers-at-risk/

Every fact above is drawn from the vendor's public documentation, reviewed by a human, and version-stamped. Monitored daily for changes.

Control mapping

Obligations this vendor triggers, each attributable to the fact it rests on — for your supplier register, not a compliance determination.

• EU AI Act Art. 50 — Transparency obligations for AI systemsok

  trains_on_input = no. Vendor states inputs are not used for training.

• EU AI Act Art. 26 — Obligations of deployers of high-risk AI systemsapplies

  Applies to your organisation as deployer, independent of vendor. Assign human oversight, keep logs, and monitor operation where this tool is used in a high-risk context (Annex III duties apply from 2 Dec 2027).

• ISO/IEC 27001 A.5.19 — Information security in supplier relationshipsapplies

  Windsurf (Codeium) processes organisational data as a supplier. Include this vendor in the supplier register and risk assessment.

• ISO/IEC 27001 A.5.20 — Addressing information security within supplier agreementsok

  dpa_available = true. A data processing agreement is available and should be executed.

• ISO/IEC 27001 A.5.22 — Monitoring, review and change management of supplier servicesattention

  breach_history: Included in a 2025 third-party research report ('Forked and Forgotten') on ~94 unpatched Chromium-derived vulnerabilities affecting Cursor and Windsurf's Electron/Chromium base, exposing an estimated 1.8M developers; vendor-side data-training breach not identified. Prior incident on record — justify continued use and monitor.

• ISO/IEC 27001 A.5.23 — Information security for use of cloud servicesapplies

  Cloud AI service; trains_on_input = no. Define acceptable-use and configuration rules for this cloud service.

• ISO/IEC 42001 A.10.3 — Suppliers of AI systems and servicesapplies

  No certifications listed. No AI-management certification identified; assurance must come from your own supplier assessment.

• GDPR Art. 44–49 — International transfers of personal dataattention

  data_region = US. Processing occurs outside the EU/EEA — a transfer mechanism (SCCs or adequacy) must be in place.

• NIS2 Art. 21(2)(d) — Supply chain securityapplies

  AI vendor forms part of your ICT supply chain. In scope for entities covered by NIS2; include in supply-chain risk measures.

• DORA Art. 28 — General principles for ICT third-party riskapplies

  AI vendor is an ICT third-party service provider. For financial entities: register of information and contractual requirements apply.

Change history

No material changes recorded since monitoring began.