If you share sensitive information like your race, religion, or sexual orientation in chats with AI characters, Character.AI may collect and process that information, even though it advises you not to share it.
This analysis describes what Character.AI's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Users of AI chat platforms commonly share personal details in the course of conversation, and this provision acknowledges that sensitive categories of data may be collected through those interactions, with the policy's primary protection being an advisory warning rather than a technical or contractual restriction on collection.
Previous version had no excerpt; current version now provides comprehensive explanation of what constitutes sensitive information and explicitly states it is not required for service use.
View full change record →Sensitive personal details you share in AI character conversations, such as information about your health, beliefs, or sexuality, may be collected and processed by Character.AI, with the company's main safeguard being a recommendation not to share such information rather than a commitment not to process it.
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We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"Information you provide directly to us might also include information that may be treated as sensitive under applicable laws, such as login credentials, personal communications received or sent using our Services, or other information about yourself that you choose to provide when using our Services (e.g., if you voluntarily post user content revealing your race, religion, or sexual orientation). Sensitive personal information is not required or necessary to use the Services – please do not include any sensitive personal information in your interactions with us or the Services.— Excerpt from Character.AI's Character.ai Privacy Policy
REGULATORY LANDSCAPE: Sensitive personal information categories including race, religion, and sexual orientation are special category data under GDPR Article 9, requiring explicit consent or another enumerated basis for processing. Under CCPA, sensitive personal information has an expanded definition and specific opt-out rights. The FTC and EU data protection authorities are the primary enforcement bodies. The policy's acknowledgment that such data may be collected without articulating a specific processing basis or restriction in the base document creates regulatory exposure. GOVERNANCE EXPOSURE: High. Collecting special category data through an open-ended conversational AI interface without robust consent or processing restrictions represents significant GDPR Article 9 exposure. The policy's approach of discouraging rather than preventing sensitive data collection may be insufficient as a compliance mechanism under GDPR, which requires explicit consent or a documented enumerated basis for special category processing. JURISDICTION FLAGS: EU and UK users have the strongest protections, as GDPR Article 9 imposes strict requirements on special category data. California's CCPA defines sensitive personal information broadly and grants opt-out rights. Illinois, Colorado, Connecticut, and other US states with comprehensive privacy laws also have sensitive data provisions that may be engaged. Healthcare and mental health disclosures in chat may additionally engage HIPAA considerations if the platform is ever used in a clinical context, though this is not indicated by the document. CONTRACT AND VENDOR IMPLICATIONS: If sensitive personal data flows to advertising and analytics vendors disclosed in Section 3, those data processing relationships require heightened scrutiny under GDPR Article 9 and CCPA. Vendor contracts should specify restrictions on sensitive data use. The policy's disclosure that such data may be collected through normal use without a specific restriction mechanism may complicate vendor contractual warranties. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the AI model training use of chat data includes processing pipelines that encounter special category data, and if so, document the GDPR Article 9 basis. Technical controls to detect and restrict special category data in training pipelines should be evaluated. The adequacy of an advisory warning as a substitute for affirmative consent or processing restrictions should be assessed against applicable law in key jurisdictions.
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Users of AI chat platforms commonly share personal details in the course of conversation, and this provision acknowledges that sensitive categories of data may be collected through those interactions, with the policy's primary protection being an advisory warning rather than a technical or contractual restriction on collection.
Sensitive personal details you share in AI character conversations, such as information about your health, beliefs, or sexuality, may be collected and processed by Character.AI, with the company's main safeguard being a recommendation not to share such information rather than a commitment not to process it.
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