Provision record
DocuSign · DocuSign Privacy Statement · View original document ↗

AI Model Training Using Customer Data

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Document Record

What it is

The notice states that DocuSign trains AI models using de-identified customer data only where customer consent has been obtained, and that systems are designed to avoid using personal information for AI training without consent.

This analysis describes what DocuSign'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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes the conditions under which DocuSign may use customer data for AI model development, requiring consent and de-identification as stated preconditions. The notice does not specify the consent mechanism or what 'de-identification' standard is applied, which may require evaluation under applicable AI governance frameworks, particularly GDPR and emerging EU AI Act requirements.

Interpretive note: The notice does not specify the consent mechanism, de-identification standard, or customer opt-out process for AI training, creating interpretive uncertainty about the operational scope of this provision.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, DocuSign states it uses de-identified customer data to train AI models only with customer consent, and that a separate carve-out explicitly prohibits using Google Workspace API data for generalized AI or ML model training. The agreement does not describe the specific opt-in mechanism or de-identification methodology applied.

Cross-platform context

See how other platforms handle AI Model Training Using Customer Data and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Building, training and maintaining our artificial intelligence models through machine learning that power certain of our Services using de-identified Customer Data (with customer consent)... We intentionally design our systems with functionality to avoid training models using personal information that customers may enter into our Services (except when we have consent from a customer to do so). Docusign is committed to developing our Services that involve AI technology in accordance with our AI Innovation Principles.

Excerpt from DocuSign's Privacy Statement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
DocuSign Privacy Statement
Entity
DocuSign
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014904
Document ID
CA-D-00198
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
db171ce667d98db1d8936fb125acc66e0d283cc7f0c00e08307fb68fd757092c
Analysis generated
July 9, 2026 06:43 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: DocuSign
Document: DocuSign Privacy Statement
Record ID: CA-P-014904
Captured: 2026-07-09 06:43:10 UTC
SHA-256: db171ce667d98db1…
URL: https://conductatlas.com/platform/docusign/docusign-privacy-statement/provision/CA-P-014904/ai-model-training-using-customer-data/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does DocuSign's AI Model Training Using Customer Data clause do?

This provision establishes the conditions under which DocuSign may use customer data for AI model development, requiring consent and de-identification as stated preconditions. The notice does not specify the consent mechanism or what 'de-identification' standard is applied, which may require evaluation under applicable AI governance frameworks, particularly GDPR and emerging EU AI Act requirements.

How does this clause affect you?

Under this provision, DocuSign states it uses de-identified customer data to train AI models only with customer consent, and that a separate carve-out explicitly prohibits using Google Workspace API data for generalized AI or ML model training. The agreement does not describe the specific opt-in mechanism or de-identification methodology applied.

Is ConductAtlas affiliated with DocuSign?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by DocuSign.