OpenAI states that its services are not for children under 13 and that it does not intentionally collect data from them; if it discovers a child's data has been collected, it states it will delete it.
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 provision establishes the age threshold for service eligibility and invokes COPPA compliance obligations; the 'knowingly' qualifier means enforcement depends on OpenAI's ability to detect underage users, which relies primarily on age declared at registration.
The updated policy explicitly discloses that OpenAI receives information from advertisers and other data partners for Free and Go users, and uses this data to personalize ads and measure ad effectiveness. The policy now states that Free and Go users can control what data OpenAI uses to personalize ads through advertising controls in account settings. This represents clarified disclosure of an existing practice rather than a new authorization.
View change record →The updated privacy policy now explicitly states that OpenAI receives information from advertisers and other data partners, which is used to personalize ads shown to Free and Go users and to measure the effectiveness of those ads. For example, the policy notes that OpenAI could receive information about purchases users make from advertisers. The policy now includes a dedicated section on ad personalization and measurement as a primary use of personal data for these user tiers. You can manage what data OpenAI uses for ad personalization by accessing the advertising controls in your account settings or by using the Data Controls option.
View change record →The updated policy now explicitly authorizes OpenAI to promote products and services to users through direct marketing on third-party properties and to share limited information with select marketing partners (who are not service providers) to support these efforts. The policy states that some marketing partners may receive information through cookies and similar technologies. The revised terms establish that these marketing practices are subject to user choices and controls, with additional information and opt-out options available. You can make choices about the use of your information for third-party product promotion purposes through controls referenced in the policy.
View change record →The policy states that users under 13 are not permitted to use OpenAI services and that data collected from such users will be deleted if discovered; parents who believe their child has created an account can request deletion through privacy.openai.com.
How other platforms handle this
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.
to object to profiling activities based on our own legitimate interests
"Our services are not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.Excerpt from OpenAI's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which prohibits operators from collecting personal information from children under 13 without verifiable parental consent.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision establishes the age threshold for service eligibility and invokes COPPA compliance obligations; the 'knowingly' qualifier means enforcement depends on OpenAI's ability to detect underage users, which relies primarily on age declared at registration.
The policy states that users under 13 are not permitted to use OpenAI services and that data collected from such users will be deleted if discovered; parents who believe their child has created an account can request deletion through privacy.openai.com.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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