Provision record
OpenAI · OpenAI Data Processing Addendum · View original document ↗

OpenAI imposes comparable obligations on Sub-Processors

High severity Explicit document language Common · 288 of 352 platforms
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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

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 4429 other provisions on other platforms.

How other platforms handle this

Ancestry Medium

These companies are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.

Tinder Medium

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...

Skillshare Medium

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...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
OpenAI shall enter into contractual arrangements with each Sub-Processor that imposes on them obligations comparable to those imposed on OpenAI under this DPA.

Excerpt from OpenAI's Data Processing Addendum

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
OpenAI Data Processing Addendum
Entity
OpenAI
Document last updated
May 11, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-061517
Document ID
CA-D-00757
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3a1b6bc316e690b84874f1ab6de51ac037a8084441b88c58ba8dec245e06e17d
Analysis generated
July 9, 2026 03:35 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Data Processing Addendum
Record ID: CA-P-061517
Captured: 2026-07-09 03:35:12 UTC
SHA-256: 3a1b6bc316e690b8…
URL: https://conductatlas.com/platform/openai/openai-data-processing-addendum/provision/CA-P-061517/openai-imposes-comparable-obligations-on-sub-processors/
Accessed: Aug. 11, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does OpenAI's OpenAI imposes comparable obligations on Sub-Processors clause do?

The clause states: “OpenAI shall enter into contractual arrangements with each Sub-Processor that imposes on them obligations comparable to those imposed on OpenAI under this DPA.”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.