Change record
CA-C-004974
Microsoft Privacy Statement (Legacy)
Entity
Date detected
September 10, 2026
Severity
Direction
Negative
Taxonomy
Data collection expansion
Changes
+3 sentences added · −4 sentences removed · 17 sentences modified

Impact Summary

Medium Negative for users
Affected users
All users Microsoft Copilot users Microsoft 365 subscribers

Microsoft updated its privacy statement in an update detected on September 10, 2026, restructuring how it describes Copilot data usage and user controls. The revised language expands device data collection to explicitly include 'interactions with our websites and apps', removes references to Microsoft 365 Copilot as a distinct consumer product, and replaces specific opt-out language with a broader personalization control framework. Users signed into Microsoft Copilot can now manage memories and personalization settings, but the updated terms also introduce the ability for Microsoft to personalize the service using data from other Microsoft products like Bing and Edge without explicitly stating this requires prior opt-in.

1 new obligation 2 obligations expanded 1 protection removed

Consumers: Microsoft now explicitly collects data about how you use its web and app properties, not just device information.

Consumers: Microsoft may now use your activity on Bing, Edge, or MSN to personalize your Copilot experience unless you disable the setting.

Consumers: Prior explicit opt-out language for AI model training was removed; training practices now described in separate Transparency Note document.

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What this means for you

The updated statement expands what device data Microsoft collects to explicitly include interactions with Microsoft websites and apps, moving beyond prior language that mentioned only device details, hardware, and settings. The terms now authorize Microsoft to personalize Copilot using conversation history (including saved memories) and optionally using data from other Microsoft products like Bing, Edge, and MSN. You can manage memories and control personalization features using settings within Microsoft Copilot at any time.

What you can do

Review privacy controls within Microsoft Copilot settings to understand and configure memory management and personalization preferences.

Consult the Microsoft Copilot Privacy Center and Transparency Note for detailed information about data practices and AI training.

Historical Context

ConductAtlas has recorded 6 material changes to this document over 188 days of monitoring (since March 2026). An additional minor or cosmetic changes were excluded.

6 of Microsoft's significant changes have been classified as negative for consumers.

Key Clauses Affected

Device data collection expansion

Now explicitly includes interactions with Microsoft websites and apps, broadening scope beyond hardware and settings.

Cross-product personalization authorization

Adds explicit authority to personalize Copilot using data from Bing, Edge, and MSN without requiring prior consent.

Removal of AI model training opt-out language

Explicit opt-out mechanism for AI training was removed; training practices now referenced in external Transparency Note.

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
038c77f4e0e0960bdacc607fc616e0fe9c09d77f584fa91f8e3c4c3050fea6dd
August 1, 2026 00:10 UTC
✓ Verified
Current Version
6fe4847c93c165957d83e4929926c8692eb8556741fb8143dac5910d906c4893
September 10, 2026 00:09 UTC
✓ Verified
Change Detected
September 10, 2026 00:09 UTC
Analysis Methodology
Citation Record
Entity: Microsoft
Document: Microsoft Privacy Statement (Legacy)
Record ID: CA-C-004974
Captured: 2026-09-10 00:09:02 UTC
URL: https://conductatlas.com/change/2026-09-10-microsoft-microsoft-privacy-statement-legacy-4974/
Accessed: Sept. 10, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

This change restructures Microsoft's Copilot data governance by expanding device data collection scope, broadening personalization mechanisms to include cross-product data usage, and removing previous language about opting out of AI model training. The change consolidates …

🔒 Full institutional analysis

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-004974.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
Microsoft Privacy Statement (Legacy)
Entity
Microsoft
Captured
September 10, 2026
Source URL
https://www.microsoft.com/en-us/privacy/privacystatement
Other changes to Microsoft Privacy Statement (Legacy)
Previous change Aug 1, 2026
Microsoft updated its Privacy Statement in an update detected on August 1, 2026, making changes primarily to document structure, formatting, …
Low Neutral
View full version history →
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