OpenAI automatically collects technical data about your device and how you use its services, including your IP address, browser type, search queries, and feature usage patterns.
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The clause establishes the operational scope of data collection that occurs passively during service use, defining the categories of technical and behavioral information the entity may process as part of service delivery and system administration.
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 →Every session with OpenAI services generates device and behavioral data that OpenAI collects automatically; this includes your IP address and usage patterns, which can be used to infer location and behavior even without account registration.
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"Usage Data. When you use our Services, we automatically collect certain technical information about your device and how you interact with our Services, such as your IP address, browser type, operating system, referring URLs, device identifiers, and cookie data, as well as information about how you use and interact with our Services, such as the date and time of your visit, the features you use, searches you conduct, and other usage information.— Excerpt from OpenAI's OpenAI Privacy Policy
(1) REGULATORY LANDSCAPE: Automated collection of IP addresses and device identifiers constitutes processing of personal data under GDPR, requiring a disclosed legal basis. Cookie data collection may additionally require compliance with ePrivacy Directive requirements in the EU, including consent for non-essential cookies. The FTC Act and CCPA apply to US users regarding disclosure and limitation of automated data collection. (2) GOVERNANCE EXPOSURE: Low to Medium. Automated collection of usage and device data is standard industry practice, but the breadth of categories collected (IP, device identifiers, browsing behavior, feature usage) creates a detailed behavioral profile that may engage data minimization obligations. Cookie consent mechanisms should be verified for ePrivacy compliance in the EU. (3) JURISDICTION FLAGS: EU ePrivacy Directive and national cookie laws apply to EEA users and may require granular consent for non-essential cookies. California users have CCPA rights regarding the categories of data collected. Illinois BIPA would apply only if biometric identifiers were collected, which is not indicated by this provision. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers deploying OpenAI in workplace contexts should assess whether employee device and usage data is collected and whether employee privacy notices accurately disclose this. (5) COMPLIANCE CONSIDERATIONS: Review cookie consent banners for ePrivacy compliance; assess whether device identifier collection aligns with data minimization principles; confirm that usage data is included in DSAR responses when users request their personal data.
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The clause establishes the operational scope of data collection that occurs passively during service use, defining the categories of technical and behavioral information the entity may process as part of service delivery and system administration.
Every session with OpenAI services generates device and behavioral data that OpenAI collects automatically; this includes your IP address and usage patterns, which can be used to infer location and behavior even without account registration.
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