This analysis describes what OpenAI'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 establishes the legal mechanism OpenAI Ireland Limited uses to legitimize international transfers of EEA and Swiss Data, which is a core requirement under European data protection law.
Interpretive note: The excerpt is truncated after 'SCCs'; the reference to adequacy decisions is inferred from standard SCC transfer framework language and is noted in omitted_material. Confidence is medium because the full alternative bases are not fully quoted.
EEA and Swiss Data transferred by OpenAI Ireland Limited outside the EEA or Switzerland is protected by Standard Contractual Clauses or, where applicable, an adequacy decision.
How other platforms handle this
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
"To the extent OpenAI Ireland Limited transfers EEA and Swiss Data to other OpenAI Affiliates or third parties outside the European Economic Area or Switzerland...it will do so on the basis of agreements containing SCCs...Excerpt from OpenAI's Data Processing Addendum
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This establishes the legal mechanism OpenAI Ireland Limited uses to legitimize international transfers of EEA and Swiss Data, which is a core requirement under European data protection law.
EEA and Swiss Data transferred by OpenAI Ireland Limited outside the EEA or Switzerland is protected by Standard Contractual Clauses or, where applicable, an adequacy decision.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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