ModelCharter

Is Windsurf GDPR compliant?

Yes

Cognition (formerly Codeium) · Coding

Yes. Cognition (formerly Codeium) offers a Data Processing Agreement (DPA) for Windsurf, the baseline GDPR control when a vendor processes personal data on your behalf.

What we checked

This assessment separates the consumer product from any business plan. It uses the vendor documents linked below; an unverified item is not a pass.

Data Processing Agreement
Confirmed
Cognition (formerly Codeium) publishes a DPA. A DPA is necessary but does not replace your own lawful-basis, DPIA and transfer assessment.
EU data residency
Not verified
No EU-residency option was confirmed in the sources reviewed for this profile.
Default data training
Opt-out required
Cognition may use customer data for model training by default; the free tier has no stated opt-out.
Business-tier training
No by default
Paid tiers can opt out (which also enables Zero Data Retention); Enterprise carries a no-training guarantee.
Practical risk: Cognition holds SOC 2 Type 2 and ISO 27001, but Windsurf's own terms say customer code may be used for training by default; the opt-out with Zero Data Retention is available only on paid tiers, and free-tier users have no documented opt-out. HIPAA and EU residency are unconfirmed.

How to make a decision

Check the precise account tier, written contract and intended data before approving Windsurf. A security certification, DPA or setting can apply to only part of a vendor's service. Keep the source links with your supplier review and revisit them when the vendor changes its terms.

More on Windsurf

See the full Windsurf risk profile, with every data-handling fact and its source, or browse all rated AI tools.