Change record
CA-C-001863
OpenAI Privacy Policy
Entity
Date detected
April 22, 2026
Effective date
April 22, 2026
Severity
Direction
Negative
Taxonomy
Transparency removal
Changes
−10 sentences removed · 12 sentences modified

Impact Summary

Medium Negative for users
Affected users
All users US users

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.

2 protections removed

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

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

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What this means for you

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.

Historical Context

This is the 2nd significant Transparency Removal change OpenAI has made since ConductAtlas began monitoring.

ConductAtlas has recorded 2 material changes to this document over 43 days of monitoring (since March 2026). An additional minor or cosmetic changes were excluded.

2 of OpenAI's significant changes have been classified as negative for consumers.

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 Insight.

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: Aug. 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
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 …

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Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.

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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

View complete diff →

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 10, 2026
OpenAI's privacy policy underwent substantial restructuring in an update detected on March 10, 2026. The policy removed multiple standalone sections …
High Negative
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 →
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