CA-C-001503
OpenAI — OpenAI Privacy Policy
Entity
Date detected
May 1, 2026
Effective date
May 1, 2026
Severity
Direction
Neutral
Affected users
all users EU users UK users EEA users
Taxonomy
Advertising use expansion
Changes
+9 sentences added · 12 sentences modified
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Event Summary

OpenAI updated its Privacy Policy on May 1, 2026 to add explicit language about direct marketing to users and disclosure of data sharing with marketing partners. The policy now states that OpenAI will promote products and services to users through direct marketing on third-party properties, subject to user choices and controls. Additionally, the policy introduces a new category called 'Vendors, Service Providers, and Marketing Partners,' specifying that OpenAI shares limited information with select marketing partners who are not traditional service providers to help promote products and assess marketing effectiveness. Users can now make choices about the use of their information for third-party product promotion purposes.

MEDIUM

Consumer Impact

The updated policy now explicitly authorizes OpenAI to promote products and services to users through direct marketing on third-party properties and to share limited information with select marketing partners (who are not service providers) to support these efforts. The policy states that some marketing partners may receive information through cookies and similar technologies. The revised terms establish that these marketing practices are subject to user choices and controls, with additional information and opt-out options available. You can make choices about the use of your information for third-party product promotion purposes through controls referenced in the policy.

Governance Analysis

The updated terms establish explicit authorization for OpenAI to engage in direct marketing to users and to share data with non-service-provider marketing partners to support those efforts. This change operationalizes a new category of data recipient and marketing use case that was not previously disclosed with this level of specificity. The addition of user-control mechanisms suggests OpenAI intends to scale direct-marketing activities while maintaining an option for users to opt out, which affects how personal data flows through the company's marketing operations.

Available Actions

Review the updated privacy policy language describing direct marketing practices and marketing partner sharing.

Access the 'learn more' links provided in the policy to understand the specific opt-out or control mechanisms available for third-party product promotion.

Configure your preferences regarding cookies and direct marketing through the controls referenced in the updated policy.

If No Action Is Taken

Your information may be used for direct marketing to you on third-party platforms as described in the updated terms.

Information about your use of OpenAI services may be shared with marketing partners to assess the effectiveness of product promotion efforts.

Cookies and similar technologies may be used to share information with marketing partners unless you exercise available controls.

Historical Context

ConductAtlas has recorded 2 material changes to this document (since April 2026). An additional minor or cosmetic changes were excluded.

Key Clauses Affected

Direct Marketing Authorization

Policy now explicitly permits OpenAI to promote products and services through direct marketing on third-party properties, subject to user choices and controls.

Marketing Partner Data Sharing

Policy introduces new disclosure that OpenAI shares limited information with select marketing partners (not traditional service providers) to assess effectiveness of product promotion efforts.

Cookie-Based Information Sharing with Marketing Partners

Policy clarifies that some marketing partners may receive information through cookies and similar technologies.

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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
65969d4b3896bcb061d05a5a1fdcbdd8c2779510513f6eeb8676ac81bb99572e
April 22, 2026 06:01 UTC
✓ Verified
Current Version
f622170ac3fd5bc0aa2f792a14e4083ea4f4840d34ec799cd7561789d95158e3
May 1, 2026 06:00 UTC
✓ Verified
Change Detected
May 1, 2026 06:00 UTC
Analysis Methodology
✓ Verified
Source Document
https://openai.com/policies/privacy-policy
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-C-001503
Captured: 2026-05-01 06:00:38 UTC
URL: https://conductatlas.com/change/2026-05-01-openai-openai-privacy-policy-1503/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

Impact Summary

1
New obligations
1
Expanded
Consumers Added

OpenAI now discloses that it will use your information to market its products on third-party platforms, but you can control whether this happens.

Consumers Expanded

OpenAI now shares information with third-party marketing partners (not just operational vendors) to help promote its services, and these partners may receive data through cookies.

For legal and compliance teams

Institutional Analysis

Assessment

OpenAI's Privacy Policy now explicitly discloses direct marketing practices and introduces a new data-sharing category for non-service-provider marketing partners. This change operationalizes marketing disclosures that may trigger obligations under GDPR (lawful basis for direct marketing), CCPA/CPRA (opt-out rights for sale or sharing), and similar privacy regimes. Organizations that have OpenAI in their vendor stack should evaluate whether their own privacy notices and vendor agreements adequately reflect these third-party marketing disclosures, and whether downstream consumer consent mechanisms (if required by applicable law) cover marketing partner sharing. No immediate enforcement risk is evident from the change itself, but the expanded transparency may signal OpenAI's intention to scale direct-to-consumer marketing activities.

Regulatory Exposure

GDPR (lawful basis for direct marketing; international data transfers to marketing partners); CCPA/CPRA (opt-out rights for sale or sharing of personal information); UK PECR (electronic marketing to individuals); ePrivacy Directive (cookie consent); similar state and international privacy laws.

Full compliance analysis

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

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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-001503.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
OpenAI Privacy Policy
Entity
OpenAI
Captured
May 1, 2026
Source URL
https://openai.com/policies/privacy-policy
Other changes to OpenAI Privacy Policy
Previous change Apr 22, 2026
OpenAI removed language describing a separate category of marketing partners and the cookie-based data sharing practices used with those partners. …
Medium Negative
Next change May 2, 2026
OpenAI added a new statement clarifying that sensitive data is not processed to infer characteristics about users. The policy also …
Low Neutral
View full version history →
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