“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...”
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 your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards...
All transfers of information to service providers are covered by appropriate data agreements and, in the case of cross-border data transfers, legal mechanisms for doing so.
Any information you provide through use of the Sites may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside.
"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 281 platforms. See the full comparison.
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