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
This distinction allocates data governance responsibility between Microsoft and its customers. In enterprise contexts, customers retain primary control over data policies and compliance obligations, while in consumer contexts, Microsoft's stated privacy practices establish the governing framework for personal data handling.
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 →For users of consumer products and services, this provision establishes that Microsoft acts as the data controller, meaning Microsoft's privacy statement—rather than a customer's policies—governs how personal data is processed. This designation defines Microsoft's direct responsibility for data handling decisions in consumer product contexts.
How other platforms handle this
We collect and receive information as a data controller for our own purposes and as a data processor on behalf of our customers. When our customers use our products to process data about their end users and employees, we act as a data processor on their behalf. Our customers, as data controllers, de...
This Privacy Policy does not apply where Anthropic acts as a data processor and processes personal data on behalf of commercial customers using Anthropic's Commercial Services – for example, your employer has provisioned you a Claude for Work account, or you're using an app that is powered on the ba...
Mistral AI is authorized to process the Personal Data as Controller for the purposes of: Automated moderation, including abuse monitoring on our APIs (except, in this last case, when zero data retention has been activated), to enforce the Agreement.
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"When Microsoft processes personal data in connection with enterprise and developer products—including enterprise online services and enterprise software—Microsoft acts as a data processor, processing personal data on behalf of the customer (the data controller). In these situations, the customer's privacy policies govern the use of personal data, not this privacy statement. When Microsoft processes personal data in connection with consumer products and services, Microsoft acts as a data controller.— Excerpt from Microsoft's Microsoft Privacy Statement (Legacy)
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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This distinction allocates data governance responsibility between Microsoft and its customers. In enterprise contexts, customers retain primary control over data policies and compliance obligations, while in consumer contexts, Microsoft's stated privacy practices establish the governing framework for personal data handling.
For users of consumer products and services, this provision establishes that Microsoft acts as the data controller, meaning Microsoft's privacy statement—rather than a customer's policies—governs how personal data is processed. This designation defines Microsoft's direct responsibility for data handling decisions in consumer product contexts.
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