CA-C-001863
OpenAI — OpenAI Privacy Policy
Entity
Date detected
April 22, 2026
Effective date
April 22, 2026
Severity
Direction
Negative
Affected users
all users US users
Taxonomy
Transparency removal
Changes
−10 sentences removed · 12 sentences modified
Share 𝕏 Share in Share 🔒 PDF
Watch OpenAI Get alerts when this policy changes.
Watch — Free

Event Summary

OpenAI removed language describing a separate category of marketing partners and the cookie-based data sharing practices used with those partners. The updated policy now consolidates all third-party recipients under a single "Vendors and Service Providers" category and removes explicit disclosure of cookie-based marketing partner data sharing. Separately, language stating that OpenAI does not process sensitive data for inferring characteristics about users has been deleted.

MEDIUM

Consumer Impact

The updated policy removes explicit language describing how OpenAI shares personal data with marketing partners through cookies and similar technologies. The policy previously stated that 'some of these partners may receive information through cookies and similar technologies' and offered users choices to learn more and control that sharing; this language is now absent. Additionally, the updated policy deletes a statement that OpenAI does not process sensitive data for the purpose of inferring characteristics about users, removing a specific protection that was previously disclosed.

Governance Analysis

The updated terms remove explicit transparency around how OpenAI shares data with marketing partners via cookies and remove a stated protection against sensitive data inference. These removals reduce explicit consumer-facing disclosure of specific data practices that were previously described. Whether these practices continue under alternative authorization or have ceased is now unclear from the policy text alone, which may affect how consumers and regulators assess data handling practices.

If No Action Is Taken

The policy terms will apply as written; users will no longer have explicit policy language describing cookie-based marketing partner data sharing or limitations on sensitive data inference

Key Clauses Affected

marketing partner disclosure removal

Language describing cookie-based data sharing with marketing partners and user control options is deleted

sensitive data inference statement removal

Statement that sensitive data is not processed for inferring user characteristics is deleted

vendor consolidation

Separate 'marketing partners' category is removed and consolidated into 'Vendors and Service Providers'

Full clause-by-clause analysis available with Professional.
These clauses may change again. Get alerted when they do. Watch OpenAI — Free

This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
6b353c1589a72be1536014a6333192a72a329bfe07d9e879dd16e0b7b3a60cbd
May 2, 2026 06:02 UTC
✓ Verified
Current Version
65969d4b3896bcb061d05a5a1fdcbdd8c2779510513f6eeb8676ac81bb99572e
April 22, 2026 06:01 UTC
✓ Verified
Change Detected
April 22, 2026 06:01 UTC
Analysis Methodology
✓ Verified
Source Document
https://openai.com/policies/privacy-policy
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-C-001863
Captured: 2026-04-22 06:01:14 UTC
URL: https://conductatlas.com/change/2026-04-22-openai-openai-privacy-policy-1863/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

Impact Summary

2
Protections removed
Consumers Removed

OpenAI no longer explicitly states in its policy that cookies may be used to share your data with marketing partners

Consumers Removed

OpenAI no longer explicitly states it does not use sensitive data to make inferences about your characteristics or interests

For legal and compliance teams

Institutional Analysis

Assessment

OpenAI removed language disclosing cookie-based marketing partner data sharing and a statement that sensitive data is not used for inferential profiling. These deletions reduce explicit transparency disclosures without clarifying whether the practices continue under different language or have ceased. Organizations using OpenAI services should clarify whether these practices persist and how they are now described. Regulatory exposure depends on applicable privacy law (GDPR, CCPA, etc.), which may require affirmative disclosure of such practices regardless of whether OpenAI's policy text describes them. The removal of sensitive data inference language creates potential GDPR/state privacy law compliance questions if the practice was previously subject to heightened restrictions.

Regulatory Exposure

GDPR, CCPA, LGPD, UK DPA 2018

Full compliance analysis

Obligation analysis, escalation trigger, board language, and recommended action.

Watcher $9.99/mo Professional $149/mo

Watcher: regulatory citations + obligations. Professional: full compliance memo.

ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001863.

Full Changes

See the full side-by-side comparison of every sentence added, removed, and modified.

🔒 Full diff — Watcher

Document Context

Version history → Policy drift analysis → Document page →
Document
OpenAI Privacy Policy
Entity
OpenAI
Captured
April 22, 2026
Source URL
https://openai.com/policies/privacy-policy
Other changes to OpenAI Privacy Policy
Previous change Mar 6, 2026
OpenAI's privacy policy was updated on March 6, 2026, with changes to how it describes data uses and disclosures. The …
Low Neutral
Next change May 1, 2026
OpenAI updated its Privacy Policy on May 1, 2026 to add explicit language about direct marketing to users and disclosure …
Medium Neutral
View full version history →
More from OpenAI
May 9, 2026 Low
OpenAI Privacy Policy

OpenAI's Privacy Policy was updated on May 9, 2026 with a single language modification in the document header. The change …

May 5, 2026 Medium
OpenAI Privacy Policy

OpenAI removed language describing advertiser data partnerships and ad personalization controls for free users, while also removing the specific statement …

May 2, 2026 Low
OpenAI Privacy Policy

OpenAI added a new statement clarifying that sensitive data is not processed to infer characteristics about users. The policy also …

Related Analysis
Privacy · May 3, 2026
OpenAI Privacy Policy Update May 2026: New Terms Authorize Advertiser Data Sharing

OpenAI expanded its data sharing terms to include third-party marketing partners. The updated policy authorizes the use of personal data fo…

Track OpenAI policy changes

Get alerted when this policy changes again — including what changed and why it matters.

Prefer a weekly summary instead?

Get the biggest policy changes across 320+ platforms every Sunday.