An artificial intelligence research company that develops and operates large language models and AI systems, including ChatGPT and GPT-4, which are used by millions of consumers worldwide for text generation, conversation, and various productivity tasks. The company's policies govern how user data is collected and used to train AI models, what content is permitted on their platforms, and the safety measures implemented to prevent harmful AI outputs, making their terms particularly significant given the personal and sensitive information users often share with AI assistants.

19 Documents
309 All provisions 70 High severity 194 Medium severity 45 Low severity
53 Changes · 12 mo 2 high
Jul 21, 2026 Last change

High, provisions that significantly limit your legal rights, authorize broad data collection, or create material financial exposure. Medium, provisions worth knowing about but with partial protections or limited scope. Low, standard terms with minimal consumer impact.

Governance Coverage
Contract Terms
69 provisions · 22 high · 35 med
Data Sharing
54 provisions · 18 high · 30 med
Acceptable Use
50 provisions · 45 high · 5 med
Data Usage
43 provisions · 24 high · 16 med
Intellectual Property
39 provisions · 15 high · 22 med
Account Control
37 provisions · 10 high · 27 med
Liability Limitation
34 provisions · 26 high · 8 med
Arbitration
34 provisions · 10 high · 19 med
Enforcement Actions
32 provisions · 21 high · 11 med
Data Retention
31 provisions · 14 high · 17 med
Quick Facts
Arbitration: Mandatory
AI Training: Disclosed (high impact)
Data Retention: Specified
Class Action: Waived
Key Governance Provisions
High Sub-processor moderation retention limited to review period

The retention and use of flagged content by sub-processors is double-limited: by time (review period only) and by purpose (assisting OpenAI's review only), constraining how sub-processors can handle …

High Snowflake data warehousing excludes ZDR customers

Customer data is sent to Snowflake for warehousing unless the customer has Zero Data Retention, making ZDR status the operative factor in whether Snowflake processes a customer's data.

High Alignment with EU AI Act Code of Practice

This clause signals that OpenAI is positioning its existing safety and security practices against an EU-level emerging legal standard, indicating the geographic scope of its compliance posture.

High App Enabling Authorizes Data Transmission

The act of using or enabling the App triggers an automatic data transmission authorization, and the receiving Application's terms—not OpenAI's—govern that data once transmitted.

High Visual Capabilities Likeness Reproduction Requires Consent

This prohibition protects individuals from unauthorized likeness reproduction and requires affirmative consent and rights clearance before such use.

Document Coverage
Systemcard Subprocessorlist Safetypolicy Privacypolicy Enterpriseterms Termsofservice Responsibleai Dataprocessingaddendum Acceptableusepolicy
Last change detected: Jul 21, 2026 Changes (12 months): 53 (2 high) Documents monitored: 19 Provisions tracked: 309
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Documents

OpenAI Sub-Processor List

Medium

This document lists the companies OpenAI shares your data with, what those companies do with it, and where in the world they process it. Your data may be handled by …

Last updated July 6, 2026 · Sub processor list
8 provisions 3 versions captured Version history →

OpenAI GPT-5.5 System Card

Medium

This document describes the safety testing OpenAI performed on GPT-5.5 and GPT-5.5 Pro before making them available, including adversarial testing focused on cybersecurity and biology risks. OpenAI states these models …

Last updated July 6, 2026 · System card
6 provisions 7 versions captured Version history →

OpenAI GPT-5 System Card

Medium

This document describes how OpenAI has built, restricted, and structured the GPT-5 model family. A real-time router—not the user—decides which model handles each query based on conversation type, complexity, and …

Last updated July 6, 2026 · System card
5 provisions 4 versions captured Version history →

OpenAI Frontier Governance Framework

Medium

This document describes how OpenAI governs the safety of its most advanced AI systems, covering serious risks like cyberattacks, biological and chemical weapons, harmful manipulation, and AI operating outside human …

Last updated July 4, 2026 · Safety policy
5 provisions 8 versions captured Version history →

OpenAI System Card GPT-4o

Last updated May 12, 2026 · System card
0 provisions 0 versions captured Version history →

OpenAI Enterprise Privacy

Medium

This document governs how OpenAI handles your business data when you use its enterprise products or API. By default, OpenAI does not use your data to train its models, and …

Last updated May 12, 2026 · Enterprise terms
10 provisions 7 versions captured 2 significant changes Version history →

OpenAI Safety Standards

Low

This document sets out OpenAI's commitments to keeping its AI systems safe and responsible — including filtering harmful content, protecting private information, and enforcing child safety protections. OpenAI publishes system …

Last updated May 12, 2026 · Responsible ai
8 provisions 4 versions captured Version history →

OpenAI API Data Usage Policies

Medium

This document sets out how OpenAI handles the data you send through its API and products. By default, OpenAI does not use your business data to train its AI models …

Last updated May 12, 2026 · Privacy policy
10 provisions 7 versions captured 2 significant changes Version history →

OpenAI Data Processing Addendum

Medium

This document sets the rules for how OpenAI handles data that business customers provide when using its services. OpenAI can only use that data as the customer instructs, and cannot …

Last updated May 11, 2026 · Data processing addendum
9 provisions 3 versions captured Version history →

OpenAI EU Terms of Use

Medium

These terms set out what you can and cannot do when using OpenAI's Services, and what OpenAI can do with the content you provide. Key points for ordinary users include …

Last updated May 11, 2026 · Terms of service
10 provisions 5 versions captured Version history →

OpenAI Business Terms

High

This agreement sets the rules for businesses using OpenAI's services: you own the outputs OpenAI generates for you, but you are responsible for everything your affiliates do under your account …

Last updated May 11, 2026 · Terms of service
10 provisions 5 versions captured Version history →

OpenAI Service Terms

Medium

These terms set out the rules for using OpenAI's services, including what OpenAI will and won't cover if you or your business face a legal claim over AI-generated content. Key …

Last updated May 11, 2026 · Terms of service
10 provisions 7 versions captured 1 significant change Version history →

OpenAI Usage Policies

Medium

OpenAI's Usage Policies, updated October 29, 2025, define what users and developers may and may not do when using OpenAI products and services. The terms explicitly prohibit a range of …

Last updated May 11, 2026 · Acceptable use policy
8 provisions 4 versions captured Version history →

OpenAI Terms of Use

High

This document establishes the terms governing user access to and use of OpenAI services, including ChatGPT, Sora, and related products. The agreement authorizes OpenAI to use content submitted by users …

Last updated May 5, 2026 · Terms of service
10 provisions 2 versions captured Version history →

OpenAI Privacy Policy

Medium

This is OpenAI's US Privacy Policy covering how the company collects and uses personal data when users interact with ChatGPT, Sora, the Atlas browser, and other consumer-facing Services. The policy …

Last updated May 5, 2026 · Privacy policy
9 provisions 19 versions captured 5 significant changes Version history →

GPT-4o System Card (PDF)

Medium

This is OpenAI's System Card for GPT-4o, a multimodal AI model that accepts text, audio, image, and video inputs and generates text, audio, and image outputs, published alongside OpenAI's Preparedness …

Last updated March 5, 2026 · System card
8 provisions 1 version captured Version history →

Terms of Use (ROW)

Medium

These are the rules for using OpenAI's Services if you are outside the United States. OpenAI can use content you submit to develop and improve its Services, and it can …

Last updated March 5, 2026 · Terms of service
10 provisions 1 version captured Version history →

Privacy Policy (ROW)

Medium

This is OpenAI's privacy policy for users outside the United States. It explains what data OpenAI collects, how it uses and shares that data, and what choices you have — …

Last updated March 5, 2026 · Privacy policy
10 provisions 1 version captured Version history →

Usage Policies

Medium

This is OpenAI's Usage Policies document, governing what users and developers may and may not do with OpenAI's products including ChatGPT, Sora, Codex, and the API. The policy prohibits a …

Last updated March 5, 2026 · Acceptable use policy
7 provisions 1 version captured Version history →

Recent Changes

July 18, 2026 · OpenAI Enterprise Privacy Medium

OpenAI modified two sentences in its Enterprise Privacy policy as detected on July 18, 2026. The first change was purely formatting, moving the title 'Enterprise privacy at OpenAI' to appear …

View change record →
July 16, 2026 · OpenAI API Data Usage Policies Medium

OpenAI modified two sentences in its Enterprise Privacy Policy, detected on July 16, 2026. The opening section now includes a formatting change (addition of 'Enterprise privacy at OpenAI' as a …

View change record →
June 12, 2026 · OpenAI Privacy Policy Medium

OpenAI's privacy policy was restructured on June 12, 2026, adding a table of contents and clarifying how personal data is used. The most material change is new language explicitly disclosing …

View change record →
June 7, 2026 · OpenAI Privacy Policy Medium

OpenAI updated its privacy policy on June 7, 2026 to add explicit language about how it collects and uses advertising data for Free and Go users. The updated policy now …

View change record →
June 2, 2026 · OpenAI Service Terms Medium

OpenAI updated its Service Terms on June 2, 2026, adding new sections governing Licensed Materials (software and code installed on customer systems) and ChatGPT Sites (a website creation feature). The …

View change record →
📈 Policy Drift Analysis View all changes →

High Severity Provisions (54)

View all high severity provisions → Compare OpenAI with other platforms →

Applicable Regulations

EU AI Act
European Union
View official text ↗
BIPA
Illinois, USA
View official text ↗
California AB 2013 AI Training Data Transparency
US-CA
View official text ↗
CCPA/CPRA
California, USA
View official text ↗
Colorado AI Act
US-CO
View official text ↗
CFAA
United States Federal
View official text ↗
Connecticut Data Privacy Act Amendments
US-CT
View official text ↗
CAN-SPAM
United States Federal
View official text ↗
DMCA
United States Federal
View official text ↗
DSA
European Union
View official text ↗
ePrivacy Directive
European Union
View official text ↗
EU AI Act - High Risk Provisions
EU
View official text ↗
FAA
United States Federal
View official text ↗
FTC Act Section 5
United States Federal
View official text ↗
GDPR
European Union
View official text ↗
Indiana Consumer Data Protection Act
US-IN
View official text ↗
Kentucky Consumer Data Protection Act
US-KY
View official text ↗
Texas AI Act
Texas, USA
View official text ↗
Trump Executive Order on AI Policy Framework
US
View official text ↗
UK GDPR
United Kingdom
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗

Related Analysis

Privacy · May 3, 2026
OpenAI Privacy Policy Update May 2026: New Terms Authorize Advertiser Data Sharing

OpenAI expanded its data sharing terms to include third-party marketing partners. The updated policy authorizes the use of personal data fo…

Dependency Governance · June 11, 2026
AI Dependency Governance: How API Terms Govern Every App Built on OpenAI, Anthropic, and Google

872 provisions across 8 AI platforms. The terms your AI provider sets become the terms your product operates under.

Platform Analysis · June 12, 2026
OpenAI Changed Its Privacy Policy 4 Times in One Week. Here Is What Actually Changed.

Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.

Regulatory Analysis · June 28, 2026
The Great American AI Act, Explained: What the First Federal AI Law Would Require

The bill does not regulate most AI startups directly. But it changes the companies they depend on. Here is what the first federal AI law wo…

Regulatory Analysis · July 8, 2026
The AI Foundation Model Transparency Act, Explained

H.R. 8094 would make the FTC the referee for AI model disclosure. It also names system cards as a way to comply, which turns a voluntary in…

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Frequently Asked Questions

What OpenAI documents does ConductAtlas track?

ConductAtlas tracks 19 OpenAI documents including terms of service, privacy policy, and other governance documents. Every document is captured daily with cryptographic verification.

How many policy changes has OpenAI made in the past year?

OpenAI has made 53 policy changes in the past 12 months across the documents ConductAtlas tracks, including 2 classified as high severity.

How many provisions has ConductAtlas classified for OpenAI?

ConductAtlas has classified 309 provisions across OpenAI's tracked documents. 70 are rated high severity, 194 medium, and 45 low.

Can I get alerts when OpenAI changes their policies?

Yes. Monitor subscribers ($4.99/month) can add OpenAI to their watchlist and receive same-day email alerts whenever any tracked document changes.