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For DocuSign services that integrate AI, the AI Attachment may include consent to use customer data to train artificial intelligence algorithms and machine learning models, with an opt-out available through the AI Data Controls Settings FAQ.
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
This provision discloses that customer data processed through AI-integrated DocuSign services may be used to train AI and machine learning models, subject to the terms of the AI Attachment. The opt-out mechanism is referenced but the scope of customer data subject to AI training use and the specific AI Attachment terms require separate review.
Interpretive note: The specific categories of customer data subject to AI training use and the full opt-out mechanism are defined in the AI Attachment for DocuSign Services, which is incorporated by reference but not reproduced in this document.
Under this clause, customers whose DocuSign services integrate AI features may have their data used to train artificial intelligence and machine learning models unless they opt out through the AI Data Controls Settings. The specific categories of customer data covered by this provision are defined in the AI Attachment for DocuSign Services rather than in these general terms.
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"For clarity, Docusign Services that utilize or integrate with AI Services (defined in the AI Attachment for Docusign Services ) are subject to the Additional Service Terms set forth in the AI Attachment for Docusign Services, which may include consent to use Customer Data to improve Docusign Services and AI Services, including without limitation, to train artificial intelligence algorithms and machine learning models. To opt out of this consent, please refer to the AI Data Controls Settings FAQ.Excerpt from DocuSign's Terms and Conditions
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 6 and 9 regarding lawful basis for processing and, where applicable, special category data, as well as GDPR Article 22 regarding automated decision-making. The CCPA and CPRA engage regarding the use of personal information for AI training as a business purpose or otherwise. The EU AI Act, once fully applicable, may impose additional transparency and human oversight requirements depending on the AI system risk classification. The FTC has issued guidance on AI training use of consumer data under its unfair and deceptive practices authority. (2) GOVERNANCE EXPOSURE: High. The provision conditions AI training data use on consent disclosed in the AI Attachment rather than these general terms, which means the operative consent mechanism and data scope are not fully assessable from this document alone. The adequacy of an opt-out model for AI training data use under GDPR's requirements for explicit consent for certain processing purposes is a live regulatory question. (3) JURISDICTION FLAGS: EU and UK customers face the highest regulatory exposure given GDPR and UK GDPR requirements for lawful basis and transparency in AI training data use. California customers should assess whether AI training use constitutes a sale or sharing of personal information under the CPRA. Illinois users should consider whether any biometric data processed through AI-integrated services engages BIPA. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should obtain and review the AI Attachment for DocuSign Services to assess the full scope of data categories subject to AI training use, the opt-out mechanism's operability, and whether data processing agreements satisfy GDPR Article 28 requirements. Vendor assessment workflows should confirm that the opt-out has been exercised where required by internal AI governance policies. (5) COMPLIANCE CONSIDERATIONS: Data protection officers should map which DocuSign services integrate AI and assess whether the opt-out has been activated for relevant accounts. Internal AI governance policies should be reviewed to determine whether customer data processed through DocuSign may be subject to AI training without explicit internal authorization. GDPR data processing agreements with DocuSign should be reviewed for alignment with the AI Attachment terms.
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This provision discloses that customer data processed through AI-integrated DocuSign services may be used to train AI and machine learning models, subject to the terms of the AI Attachment. The opt-out mechanism is referenced but the scope of customer data subject to AI training use and the specific AI Attachment terms require separate review.
Under this clause, customers whose DocuSign services integrate AI features may have their data used to train artificial intelligence and machine learning models unless they opt out through the AI Data Controls Settings. The specific categories of customer data covered by this provision are defined in the AI Attachment for DocuSign Services rather than in these general terms.
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