The policy states that when a user opts to connect device contacts, OpenAI uploads address book data including information about individuals who do not use OpenAI's services, retains that data, and uses it to notify the account holder if non-users subsequently register.
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 authorizes collection and retention of personal data from individuals who have not agreed to OpenAI's terms or privacy policy, as the data subjects are third parties whose information appears in a user's device address book. This raises questions about the notice and consent basis for processing non-user personal data under applicable privacy frameworks.
Interpretive note: The full scope of how non-user contact data is retained and used is described in a referenced help center article not included in this document, creating uncertainty about the complete operational practice.
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 →Under this provision, choosing to connect device contacts causes OpenAI to upload and retain address book data, including data about individuals who are not OpenAI users and who have not separately consented to this collection. The policy links to additional information about how uploaded contact information of non-users is used.
Cross-platform context
See how other platforms handle Contact Data Upload for Non-Users and similar clauses.
Compare across platforms →"If you choose to connect your device contacts, we upload information from your device address books and check which of your contacts also use our Services. If any of your contacts aren't yet using our Services, we'll update you if they sign up for our Services later.Excerpt from OpenAI's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision implicates CCPA and CPRA to the extent non-user contacts are California residents whose personal data is collected without their direct consent.
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This provision authorizes collection and retention of personal data from individuals who have not agreed to OpenAI's terms or privacy policy, as the data subjects are third parties whose information appears in a user's device address book. This raises questions about the notice and consent basis for processing non-user personal data under applicable privacy frameworks.
Under this provision, choosing to connect device contacts causes OpenAI to upload and retain address book data, including data about individuals who are not OpenAI users and who have not separately consented to this collection. The policy links to additional information about how uploaded contact information of non-users is used.
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