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Summary
Generated by a model from the captured document; not read by a person

This is OpenAI's US Privacy Policy covering ChatGPT and other consumer-facing services, describing what personal data OpenAI collects, how it uses that data, and what controls users have. The policy states that user-submitted content including prompts, files, images, audio, and video may be used to train OpenAI's AI models unless the user opts out, and that Free and Go tier users are subject to personalized advertising based on their ads history and interests, with data shared with select marketing partners for cross-context behavioral advertising. The policy also discloses that when users connect their device contacts, OpenAI uploads and retains information from those address books, including data about individuals who do not themselves use OpenAI's services.

Analysis

This document is OpenAI's US Privacy Policy (effective September 10, 2026), governing the collection, use, disclosure, and retention of personal data from users of OpenAI's consumer-facing services including ChatGPT, and does not apply to data processed under business API customer agreements. The policy states that OpenAI collects identifiers, device information, log and usage data, geolocation, user content including prompts, files, images, audio, and video, contact data from device address books, and advertising history and interests for Free and Go users, and authorizes use of this data to provide services, conduct research, train AI models (subject to user opt-out), and personalize and serve targeted advertisements to Free and Go users. The policy discloses sharing of limited data with select marketing partners for cross-context behavioral advertising, which the document acknowledges is regulated under certain state privacy laws, and reserves broad disclosure authority to government authorities under a multi-factor good-faith standard including 'sole discretion' determinations of policy violations; the contact data upload provision, which collects address book information about non-users and stores it to notify the account holder if those non-users later join, raises questions about consent from third parties not party to this agreement. The policy references engagement with GDPR (through a separate EEA/UK/Switzerland policy), CCPA and other US state privacy laws (through dedicated state disclosure sections and opt-out mechanisms), and COPPA (through a minimum age of 13 and parental permission requirements for users under 18); California-specific rights reporting is disclosed, and the policy references Global Privacy Control as a recognized opt-out mechanism. Material compliance considerations include the opt-out architecture for AI model training and targeted advertising, data retention carve-outs for banned accounts and legal obligations, cross-border data transfer to US-based servers under 'legally valid transfer mechanisms,' and the scope of business account administrator access to employee content.

What this means for you

The agreement authorizes OpenAI to collect and use user-submitted content including prompts, files, images, audio, and video to train AI models, subject to a user opt-out available in account settings. Under these terms, Free and Go users' advertising history and interests are collected and used to personalize ads, and limited data is shared with select marketing partners for cross-context behavioral advertising, with opt-out available through account settings, the Your Privacy Choices link, or a recognized mechanism such as Global Privacy Control. You can opt out of model training data use, control ad personalization, export your ChatGPT data, delete conversations or your account, and submit data subject requests at privacy.openai.com or dsar@openai.com.

Institutional Analysis
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5 important changes detected

20 versions captured · Latest change detected by ConductAtlas: September 2026

What changed OpenAI revised its privacy policy to remove references to Sora and Atlas browser features, while adding new disclosures about ad-related data collection for Free and Go users. The updated policy now explicitly states that Free and Go users' ads history and interests are collected, and clarifies that browser data collection applies to the in-app browser rather than a standalone Atlas browser. Several references to Sora-related content sharing and deletion options were also removed.
Why this matters The updated policy now explicitly discloses that Free and Go users' ads history and interests are collected to measure and improve ad effectiveness. Previously, this collection was referenced more generally. The policy also clarifies that browser data collection applies to the in-app browser rather than a standalone Atlas browser product. You can review your data collection settings in your account controls and export your ChatGPT history and data at any time.
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June 12, 2026

medium
What changed OpenAI's privacy policy was reorganized with a table of contents and updated to clarify advertising practices. The policy now explicitly states that for Free and Go users, OpenAI personalizes ads based on user data and measures ad effectiveness, with data received from advertisers and partners used for these purposes. Users can control ad personalization through account settings.
Why this matters The updated policy explicitly discloses that OpenAI personalizes ads shown to Free and Go users and measures ad effectiveness using data from advertisers and partners, including information about purchases you make. The policy states this personalization is subject to user controls. You can use the advertising controls in your account settings to control what data OpenAI uses to personalize ads shown on its Services.
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May 19, 2026 low

OpenAI updated its privacy policy effective May 18, 2026, and expanded the opt-out mechanism for users who are not logged in. Previously, users could opt out only via the 'Your …

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May 2, 2026 low

OpenAI added a statement that it does not process sensitive data for inferring characteristics about users. Separately, the company updated the cookie opt-out mechanism for non-logged-in users, replacing the reference …

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May 1, 2026 medium

OpenAI expanded its privacy policy to explicitly authorize sharing limited personal data with marketing partners for targeted advertising on third-party properties, and added opt-out mechanisms for this practice. Previously, the …

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Clauses withheld

We withheld clauses we had published from this document. Each withholding is recorded in our correction log:

Provisions
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Archival ProvenanceSource & Archival Record
This version captured September 11, 2026 00:01 UTC
Last successful capture October 21, 2026 00:05 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000010
Version ID CA-V-006586
SHA-256 (extracted text, extractor v5) 56aefca53409e5447ce5bd4360c4f1e712d1e0a4d651a17217edf404d0c1395f
Archived bytes SHA-256 (anchor) 874b49f75358d000337dff5c245f61479d22e3441e451c2fdce3a57112db59fd
✓ Snapshot stored ✓ Archived bytes anchored (verified Sept. 11, 2026)

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