8 Total
1 High severity
5 Medium severity
2 Low severity
Summary

This document establishes OpenAI's privacy practices for users of its products including ChatGPT, the API, and DALL-E. The policy authorizes collection of conversation content, uploaded files, device identifiers, IP addresses, and usage activity, with provisions permitting use of this data for model training except where users disable the model training toggle in Data Controls settings. The policy establishes procedures for users to submit requests for access, deletion, or correction of personal data through OpenAI's Privacy Request Form.

Technical / Legal Breakdown

This document is OpenAI's US Privacy Policy, governing how OpenAI collects, uses, shares, and retains personal data from users of its consumer and API products, including ChatGPT, DALL-E, and related services, with stated legal bases including consent, contractual necessity, and legitimate interests. The policy states that OpenAI collects name, contact information, payment details, conversation content, files and images uploaded by users, device identifiers, IP addresses, browsing activity, location data, and usage logs, and the terms authorize use of this data for service delivery, safety monitoring, model training (where users have not opted out), and marketing communications. The policy discloses that conversation content submitted through non-API consumer products may be used to train AI models unless the user disables the training toggle in settings, which is an operationally significant disclosure given the nature of inputs users submit; the terms also authorize sharing personal data with affiliated entities, service providers, advertising and analytics partners, and in connection with corporate transactions such as mergers or acquisitions. The policy engages the California Consumer Privacy Act (CCPA/CPRA), which grants California residents rights to access, delete, correct, and opt out of certain data uses, and the policy provides a dedicated Privacy Request Form for these purposes; it also references compliance with US state privacy laws more broadly, including those in Virginia, Colorado, Connecticut, and Texas. Material compliance considerations include the adequacy of the model-training opt-out mechanism under emerging US AI and privacy regulations, the classification of third-party advertising pixel data flows under CCPA's sale and sharing definitions, and the policy's assertion that it does not knowingly collect data from users under 13, which engages COPPA enforcement by the FTC.

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9 important changes detected

10 versions captured · Last updated: May 2026

What changed OpenAI modified two sentences in its US Privacy Policy on May 19, 2026. The document timestamp was updated from April 30, 2026 to May 18, 2026. More substantially, the opt-out mechanism for users who are not logged in was expanded: users can now opt out either through a new 'Settings > Data Controls' option within ChatGPT or through the existing 'Your Privacy Choices' link on the website.
Why this matters The updated policy establishes an additional pathway for users who are not logged in to opt out of data practices. Previously, the only stated opt-out mechanism for logged-out users was the 'Your Privacy Choices' link on the website. The revised language now permits logged-out users to access opt-out controls through 'Settings > Data Controls' within ChatGPT itself, in addition to the website link. You can use either method to manage your privacy preferences.
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May 14, 2026

medium
What changed OpenAI updated its privacy request procedures on May 14, 2026. Previously, the policy stated users could exercise privacy rights by submitting requests through privacy.openai.com or dsar@openai.com. The updated language now describes the four substantive privacy rights themselves—access, deletion, correction, and freedom from retaliation—rather than the submission mechanism. This shifts the policy from procedural instruction to rights enumeration, establishing explicit recognition of these privacy protections.
Why this matters The updated policy now explicitly states four privacy rights that apply depending on your location and subject to applicable exceptions: the right to know about and access your personal data in portable format, the right to request deletion, the right to correct inaccurate data, and the right to be free from retaliation for exercising these rights. Previously, the policy referenced these rights only through procedural language about how to submit requests. The explicit enumeration establishes clearer notice of what protections the policy recognizes. You can exercise these rights by submitting a request through privacy.openai.com or dsar@openai.com.
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May 11, 2026 medium

OpenAI updated its privacy policy on May 11, 2026 to explicitly authorize the collection and use of advertiser data from partners and to create a new ad personalization purpose for …

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May 9, 2026 low

OpenAI's Privacy Policy was updated on May 9, 2026 with a single language modification in the document header. The change added Persian (فارسی) to the list of available language options …

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May 5, 2026 medium

OpenAI removed language describing advertiser data partnerships and ad personalization controls for free users, while also removing the specific statement that free and go users could control ad personalization through …

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May 2, 2026 low

OpenAI added a new statement clarifying that sensitive data is not processed to infer characteristics about users. The policy also changed how users who are not logged in can exercise …

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May 1, 2026 medium

OpenAI updated its Privacy Policy on May 1, 2026 to add explicit language about direct marketing to users and disclosure of data sharing with marketing partners. The policy now states …

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April 22, 2026 medium

OpenAI removed language describing a separate category of marketing partners and the cookie-based data sharing practices used with those partners. The updated policy now consolidates all third-party recipients under a …

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March 6, 2026 low

OpenAI's privacy policy was updated on March 6, 2026, with changes to how it describes data uses and disclosures. The updated policy removed explicit language about receiving data from advertisers …

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High — 1 provision
Medium — 5 provisions
Low — 2 provisions

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Mapped Governance Frameworks

CCPA/CPRA
California, USA
View official text ↗
FTC Act Section 5
United States Federal
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GDPR
European Union
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UK GDPR
United Kingdom
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Related Analysis

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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…

Archival ProvenanceSource & Archival Record
Last Captured May 19, 2026 00:02 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000010
Version ID CA-V-002708
SHA-256 f6e00f7793672c35c649498548b2d76fde31064441e7fbea7b14cf07e27e7d58
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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