When you use Microsoft's AI tools like Copilot, your prompts and the AI's responses may be used by Microsoft to improve its AI systems. This applies across Microsoft products that include AI features.
This analysis describes what Microsoft'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
The statement authorizes use of user-generated content and AI interaction data for model training and improvement, which may affect users who share sensitive or confidential information through Copilot or other AI features in Microsoft products.
Interpretive note: The statement describes AI data use in general terms; the precise scope of what data is retained for training versus used only for inference is not fully specified in the document text provided.
The updated policy establishes additional grounds on which Microsoft may retain personal data. While the prior version tied retention to specific user expectations and available deletion controls, the revised language authorizes retention for 'operating our business, meeting our contractual and legal obligations, improving and developing our products and services, protecting the safety and security of our systems and customers, and resolving disputes.' This expands the stated purposes beyond transaction fulfillment and legal compliance. The updated policy directs users to product-specific documentation for retention details rather than providing explicit deletion procedures and timelines in the privacy statement itself.
View change record →The updated policy now grounds data retention in five broad business purposes: operating the business, meeting contractual and legal obligations, improving and developing products and services, protecting system and customer safety, and resolving disputes. Previously, the policy articulated specific criteria for determining retention periods, including customer expectations for retention until manual deletion, availability of automated deletion controls, and data sensitivity. The revised language removes these granular criteria and instead requires users to consult individual product documentation to understand when their specific data will be deleted. This shifts the burden of finding retention timelines from the main policy statement to separate product-specific documents.
View change record →The updated Privacy Statement removes previously stated language about additional rights available to European Economic Area users, narrowing the policy's explicit protections in that region. Simultaneously, the revised terms now explicitly authorize Microsoft to contact users via auto-dialer and prerecorded voice for marketing purposes, provided the user has consented to receive marketing communications to the phone number supplied. This establishes Microsoft's contractual permission to initiate automated marketing calls using artificial intelligence-generated voice technology where user consent to marketing contact has been given.
View change record →Severity downgraded from high to medium, and provision now includes detailed explanation of how AI inputs/outputs are used for model improvement and internet connectivity disclosure.
View full change record →Users interacting with Copilot or other AI-powered Microsoft features should be aware that their inputs, queries, and the generated outputs may be used to improve Microsoft's AI models, as described in the statement. Enterprise users in particular may want to confirm whether their organization's Microsoft data processing agreement limits this use.
How other platforms handle this
We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...
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...
Monitoring
Microsoft has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"We use data to provide and improve Microsoft products, including AI and Copilot capabilities. When you use AI features, we may use your inputs and the generated outputs to improve our AI models and services. Some AI features are connected to the internet and may send your queries and content to Microsoft's servers for processing.— Excerpt from Microsoft's Microsoft Privacy Statement (Legacy)
REGULATORY LANDSCAPE: This provision engages GDPR Article 6 lawful basis requirements and Article 22 on automated decision-making; the EU AI Act imposes obligations on providers of general-purpose AI models and high-risk AI systems that may apply depending on how Copilot and related models are classified; the FTC's AI-related guidance on data use and consumer protection is also relevant. Enforcement authorities include EU data protection authorities, the UK ICO, and the FTC. GOVERNANCE EXPOSURE: High. The use of user content and interaction data for AI model training is an area of active regulatory scrutiny in the EU and increasingly in U.S. states. The statement does not specify in granular detail what data is retained for training versus discarded, which creates ambiguity for compliance teams assessing GDPR data minimization and purpose limitation requirements. JURISDICTION FLAGS: EU and UK users are subject to GDPR requirements including lawful basis, purpose limitation, and data minimization, which may constrain how broadly AI training use can be asserted. California residents may have opt-out rights if AI training constitutes use of personal information in a manner covered by CCPA. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should review their Microsoft Customer Agreement and applicable data processing addenda to determine whether AI training use of customer content is excluded or limited in the enterprise context. The default consumer statement may not reflect enterprise contractual carve-outs. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether consent mechanisms for AI data use are adequate under GDPR and applicable U.S. state law; review data mapping to include AI interaction data as a processing category; and evaluate whether AI-specific privacy notices are required under emerging AI transparency obligations.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
The statement authorizes use of user-generated content and AI interaction data for model training and improvement, which may affect users who share sensitive or confidential information through Copilot or other AI features in Microsoft products.
Users interacting with Copilot or other AI-powered Microsoft features should be aware that their inputs, queries, and the generated outputs may be used to improve Microsoft's AI models, as described in the statement. Enterprise users in particular may want to confirm whether their organization's Microsoft data processing agreement limits this use.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Microsoft.