If OpenAI is sold, merged, or acquires another company, your personal data may be transferred to the new entity as part of that transaction, including during the negotiation phase before any deal closes.
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 transfer of personal data during corporate transactions, including during the negotiation phase, without requiring individual user notification prior to the transfer, which may affect the continuity of the privacy protections users accepted.
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 personal data including conversation history, account information, and usage data may be transferred to an acquiring or merging entity; users are not guaranteed advance individual notice of such a transfer under this provision's terms.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"We may share or transfer personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.Excerpt from OpenAI's Privacy Policy
REGULATORY LANDSCAPE: This provision engages CCPA and CPRA, which require that consumers be notified if their personal data is transferred to a successor entity and that the successor be bound by the original privacy policy's …
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 authorizes transfer of personal data during corporate transactions, including during the negotiation phase, without requiring individual user notification prior to the transfer, which may affect the continuity of the privacy protections users accepted.
The policy states that personal data including conversation history, account information, and usage data may be transferred to an acquiring or merging entity; users are not guaranteed advance individual notice of such a transfer under this provision's terms.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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