Provision record
OpenAI · OpenAI Privacy Policy · View original document ↗

Cross-Context Behavioral Advertising for Free and Go Users

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Document Record

What it is

The policy authorizes use of Free and Go user data to personalize in-service advertising and to measure ad effectiveness, including receipt of purchase data from third-party advertisers to assist in that measurement. Users can adjust advertising personalization through account settings.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that OpenAI receives purchase-level data from third-party advertisers about Free and Go users, which is used for ad measurement and personalization. The policy discloses this as a form of cross-context behavioral advertising or targeted advertising under US state privacy laws, with an opt-out mechanism available in account settings.

Recent Activity

This document changed recently

Medium Jun 12, 2026

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 →
Medium Jun 7, 2026

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 →
Medium May 1, 2026

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 →

Clause Stability Stable

0
Changes
6
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Change history

modified Jul 17, 2026

Excerpt was shortened by removing the opening sentence about personalizing ads and the 'Learn more' reference, focusing only on advertiser data collection.

View full change record →

Consumer impact (what this means for users)

Under these terms, Free and Go users' in-service experience includes advertising personalized using their usage data and potentially purchase data received from third-party advertisers. The agreement discloses this practice as cross-context behavioral advertising under applicable state privacy laws, and provides an opt-out via account settings or the Global Privacy Control mechanism.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Log into your OpenAI account and navigate to the advertising controls in your account settings to adjust data use for ad personalization. If not logged in, access Settings > Data Controls on ChatGPT or use the 'Your Privacy Choices' link on the OpenAI website. You may also use a Global Privacy Control-enabled browser to opt out.

Cross-platform context

See how other platforms handle Cross-Context Behavioral Advertising for Free and Go Users and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
For Free and Go users, to personalize the ads you see on our Services (subject to your settings), and to measure the effectiveness of ads shown on our Services. Learn more about ads on our services... We may receive information from advertisers and other data partners, which we use for purposes including to help us measure and improve the effectiveness of ads shown to Free and Go users on our Services. For example, we could receive information about purchases you make from these advertisers.

Excerpt from OpenAI's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The policy explicitly identifies this practice as 'targeted advertising' or sharing for 'cross-context behavioral advertising' under US state privacy laws, engaging CCPA and CPRA opt-out requirements.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-013566
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c0c49f013e1bb2dd1fa883d161d2b79a60a5914fddbd230bcaa0df5e2cfaa86e
Analysis generated
July 9, 2026 03:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-013566
Captured: 2026-07-09 03:28:49 UTC
SHA-256: c0c49f013e1bb2dd…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/provision/CA-P-013566/cross-context-behavioral-advertising-for-free-and-go-users/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does OpenAI's Cross-Context Behavioral Advertising for Free and Go Users clause do?

This provision establishes that OpenAI receives purchase-level data from third-party advertisers about Free and Go users, which is used for ad measurement and personalization. The policy discloses this as a form of cross-context behavioral advertising or targeted advertising under US state privacy laws, with an opt-out mechanism available in account settings.

How does this clause affect you?

Under these terms, Free and Go users' in-service experience includes advertising personalized using their usage data and potentially purchase data received from third-party advertisers. The agreement discloses this practice as cross-context behavioral advertising under applicable state privacy laws, and provides an opt-out via account settings or the Global Privacy Control mechanism.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.