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
Recall captures a continuous record of on-screen activity; the local-only storage commitment and the user-action requirement before any transmission are the primary privacy safeguards limiting exposure of that highly sensitive data.
Interpretive note: The clause does not define what constitutes 'user action' that would permit transmission, leaving the scope of that exception unspecified.
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 →Readers using a Copilot+ PC with Recall can rely on the fact that their captured snapshots, queries, and related data remain on their device and are not sent to Microsoft or any other party unless the user initiates that transfer.
How other platforms handle this
Developer must promptly and securely delete all Upwork User Data collected from Upwork users upon request of the Upwork user, when the Upwork user deactivates or uninstalls the Developer Application, when the Upwork user closes their account with Developer...
We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.
We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
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"Recall securely stores all captured data—including personal data like snapshots, metadata, processing results, and user queries—locally on your Copilot+ PC... This information is never transmitted off your device unless you take action...— Excerpt from Microsoft's Microsoft Privacy Statement (Legacy)
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Recall captures a continuous record of on-screen activity; the local-only storage commitment and the user-action requirement before any transmission are the primary privacy safeguards limiting exposure of that highly sensitive data.
Readers using a Copilot+ PC with Recall can rely on the fact that their captured snapshots, queries, and related data remain on their device and are not sent to Microsoft or any other party unless the user initiates that transfer.
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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