OpenAI may use what you type into ChatGPT and other services to improve its AI models, but you can turn this off in your account settings or through OpenAI's Privacy Portal.
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
The clause establishes a default practice where user content contributes to model training unless affirmative opt-out action is taken. This operational framework determines the scope of permitted use of submitted materials across the service.
The updated policy removes language describing how OpenAI uses advertiser and data partner information to personalize ads and measure ad effectiveness. The policy also removes the specific mechanism Free and Go users previously had to control ad personalization through account settings. In exchange, the policy adds explicit authorization for OpenAI to identify which of a user's contacts use OpenAI services and to monitor all content submitted on the platform for fraud and misuse detection. The authorization to monitor content and identify contacts now appears in the main policy purposes section rather than in supplementary documentation. You can review the Korea Addendum if you are located in South Korea to understand region-specific privacy rules.
View change record →The updated policy removes language that previously described ad personalization controls available to Free and Go users through account settings, though the policy continues to authorize OpenAI to personalize ads and measure their effectiveness for these user tiers. Previously, the policy explicitly stated that 'For Free and Go users, you can use the advertising controls in your account settings to control what data we use to personalize the ads we show you on our Services.' This language is no longer present in the updated version. The policy still lists ad personalization as an authorized use of personal data for Free and Go users, but no longer explicitly describes how users can access controls to manage this practice. You should verify whether advertising controls remain functional in your OpenAI account settings, as the policy no longer explicitly references them.
View change record →The updated policy removes specific language stating that OpenAI receives advertiser data to personalize ads shown to Free and Go users. It also removes reference to account-level advertising controls previously described in account settings. These removals are replaced with broader language authorizing OpenAI to promote products through direct marketing and third-party properties, subject to choices and controls, but the terms no longer explicitly describe what advertiser data is collected, from whom, or how to manage it at the account level. The policy now requires users to follow a 'learn more' link to understand ad personalization controls, rather than documenting those controls directly in the privacy policy.
View change record →If you do not opt out, the content of your conversations including questions, uploaded files, and personal information you share in prompts may be used to train OpenAI's AI models and influence future model outputs.
How other platforms handle this
After registration, you may create, upload or transmit files, documents, videos, images, data or information as part of your use of the Service (collectively, "User Content"). This includes any inputs you provide to our AI-powered support tools and outputs generated in response to your inputs. User ...
When you use AI features, any content you input into those features may be used to generate outputs. You are responsible for ensuring that any inputs you provide and outputs you use comply with these Terms and applicable law. Canva does not guarantee that AI-generated outputs will be accurate, relia...
You are responsible for your use of the Services and for any Content, including anything referenced therein, you provide, create, post, or otherwise utilize, including any inputs, prompts, outputs, and/or information obtained or created through the Services.
Monitoring
OpenAI has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"We may use your Content to train our models. You can opt out of your Content being used to train our models by following the instructions in the 'How to opt out of model training' section or by visiting our Privacy Portal. Please note that in some cases, this may limit the ability of our Services to better address your specific use case.— Excerpt from OpenAI's OpenAI Privacy Policy
(1) REGULATORY LANDSCAPE: This provision implicates GDPR Article 6 (lawful basis) and Article 9 (special category data) for EEA and UK users, as user-submitted content may include health, financial, or other sensitive information. The FTC Act Section 5 is relevant for US users regarding whether the opt-out default constitutes an unfair or deceptive practice. The EU AI Act may also engage this provision regarding transparency obligations for AI system training data. (2) GOVERNANCE EXPOSURE: High. The default opt-in to model training creates meaningful exposure under GDPR's purpose limitation and data minimization principles. If the asserted legal basis is legitimate interests, a documented balancing test is required; if consent is relied upon, pre-ticked defaults may be insufficient. The open-ended nature of 'Content' — which could include sensitive personal data shared incidentally — amplifies this risk. (3) JURISDICTION FLAGS: EEA and UK users face the highest exposure given GDPR requirements for a clear and valid legal basis. California users may have CCPA rights to know and delete data used in training. Illinois users should consider whether voice or biometric data submitted could implicate BIPA. Minors' data warrants particular scrutiny given COPPA and analogous state laws. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers integrating OpenAI via API should confirm whether their API data processing agreement excludes model training use, as the policy indicates API data may be treated differently. B2B contracts that route customer or employee data through OpenAI's services should include explicit data processing addenda clarifying training data use. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether existing privacy notices disclosed to end users accurately represent the possibility of AI model training; update data mapping records to include OpenAI as a processor or sub-processor; and review whether employee acceptable use policies address submission of confidential data to ChatGPT.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
How Meta, TikTok, and Supabase restructured governance language across documents, jurisdictions, and consent frameworks through incremental document updates.
How 10 AI platforms describe the use of user data for model training, improvement, and development, based on archived governance provisions.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
The clause establishes a default practice where user content contributes to model training unless affirmative opt-out action is taken. This operational framework determines the scope of permitted use of submitted materials across the service.
If you do not opt out, the content of your conversations including questions, uploaded files, and personal information you share in prompts may be used to train OpenAI's AI models and influence future model outputs.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.