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The statement authorizes Microsoft to use Copilot prompts, location, and related settings to deliver relevant advertising as part of the Copilot service. This applies to the consumer Microsoft Copilot website and app.
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 provision establishes that conversational input submitted to Microsoft Copilot, including user prompts, may be used to deliver advertising. The statement separately notes that Microsoft does not use email content, human-to-human chat, video calls, or personal files to target ads, but Copilot prompt data is disclosed as an advertising input.
The updated privacy statement removes the previous detailed list of third-party sources from which Microsoft obtains personal data, including data brokers, public social media posts, location service providers, co-branded partners, and developers. Under the revised language, Microsoft describes obtaining data from 'Microsoft affiliates, subsidiaries, and third parties' without specifying the categories or types of third parties as explicitly as before. The company states it has reorganized the document for greater clarity and accessibility, but the operational effect is that users receive less specific disclosure about where their data originates from outside Microsoft.
View change record →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 →Under this provision, prompts and location data submitted to consumer Microsoft Copilot may be used to deliver personalized advertising. Users can opt out of personalized advertising via the Microsoft Privacy Dashboard or by enabling the Global Privacy Control browser signal.
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"When you use Microsoft Copilot, it will use your prompts, location, language, and related settings to provide helpful responses and improve services (including to provide relevant advertising). Microsoft Copilot also uses prompts and related data to provide and improve services, including relevant advertising.Excerpt from Microsoft's Privacy Statement (Legacy)
(1) REGULATORY LANDSCAPE: This provision implicates GDPR requirements for transparency and lawful basis for processing personal data for advertising purposes, including Article 6 and Recital 47 regarding legitimate interests for direct marketing. CCPA requires disclosure of data use for advertising and provides opt-out rights for sale or sharing of personal information. The FTC Act governs unfair or deceptive practices in data use disclosures. EU data protection authorities have examined the use of conversational AI data for advertising as a distinct and potentially high-sensitivity use case. (2) GOVERNANCE EXPOSURE: Medium. The use of conversational prompt data for advertising is disclosed in the statement, satisfying basic transparency requirements. However, the sensitivity of conversational AI inputs, which may include health-related queries, financial questions, or personal disclosures, creates governance exposure regarding whether advertising use constitutes a compatible purpose under GDPR purpose limitation principles. (3) JURISDICTION FLAGS: EU/EEA users face heightened exposure where GDPR consent requirements for behavioral advertising apply. California users have CCPA opt-out rights for sharing of personal information for advertising. The statement does not specify whether Copilot prompt data qualifies as sensitive data under U.S. state laws in contexts where users share health or financial information through Copilot. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise Copilot customers should verify that organizational data processed under enterprise agreements is excluded from advertising use. The statement indicates consumer Copilot data practices differ from enterprise Copilot offerings, but procurement teams should confirm contractual protections are in place. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether consent or opt-out mechanisms for advertising use of Copilot prompt data are surfaced at the point of Copilot use, not only in the privacy statement. Data classification frameworks should account for the potential sensitivity of conversational AI inputs used for advertising purposes.
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This provision establishes that conversational input submitted to Microsoft Copilot, including user prompts, may be used to deliver advertising. The statement separately notes that Microsoft does not use email content, human-to-human chat, video calls, or personal files to target ads, but Copilot prompt data is disclosed as an advertising input.
Under this provision, prompts and location data submitted to consumer Microsoft Copilot may be used to deliver personalized advertising. Users can opt out of personalized advertising via the Microsoft Privacy Dashboard or by enabling the Global Privacy Control browser signal.
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