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The policy states that following a deletion request, personal data is removed within 30 days, subject to exceptions for legal obligations, fraud and abuse prevention, security, and financial record-keeping; content already de-identified and used for model training is not recoverable through deletion.
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 a 30-day deletion timeline with multiple categorical exceptions, and separately acknowledges that content already de-identified and incorporated into model training datasets is not subject to the deletion mechanism, which is a practical limitation on the scope of the deletion right for users who have not opted out of model training.
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 agreement establishes a 30-day timeline for deletion of personal data following a user request, subject to exceptions for legal requirements, fraud and abuse, security, and financial record-keeping. Content that has already been de-identified and disassociated from a user account for model training purposes is stated to fall outside the scope of the deletion mechanism.
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"Once you choose to delete Personal Data, we will remove it from our systems within 30 days unless we need to retain it for longer as described below, or it has already been de-identified and disassociated from your account when you allow us to use your Content to improve our models. Information we retain for longer for legitimate security, safety, or legal reasons: In some cases, we need to retain Personal Data for longer even after you delete it, for example because we are legally required to, to address fraud and abuse, for security reasons, or for financial record-keeping purposes.Excerpt from OpenAI's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages CCPA and CPRA deletion right requirements, enforced by the California Privacy Protection Agency, including requirements regarding the timelines and exceptions applicable to deletion requests. GDPR Article 17 right to erasure requirements are engaged for EEA users under the separate policy. The policy's carve-out for de-identified data used in model training requires evaluation against applicable statutory definitions of de-identification and whether residual risks of re-identification exist. FTC Act standards apply to the accuracy of representations about deletion capabilities. 2) GOVERNANCE EXPOSURE: Medium. The de-identification carve-out means that users who did not opt out of model training prior to submitting a deletion request may not be able to remove their content from training datasets. This is disclosed in the policy but may not be apparent to users at the time of initial consent or at the time of a deletion request. Compliance teams should assess whether this limitation is disclosed with sufficient clarity to satisfy applicable statutory requirements. 3) JURISDICTION FLAGS: California CPRA and similar state statutes require that deletion requests be honored within specified timeframes and that exceptions be limited to those enumerated by statute. The policy's exception categories broadly track CCPA statutory exceptions, but the specific application of each exception may vary by state. EU and UK users are directed to a separate policy with potentially different deletion timelines and exception frameworks. 4) CONTRACT AND VENDOR IMPLICATIONS: Vendors and service providers processing data on behalf of OpenAI are subject to instructions that should align with these retention terms; enterprise procurement teams should confirm that sub-processor agreements reflect consistent deletion obligations. The audit record of erasure requests retained by OpenAI to verify compliance is a standard practice and represents a minimal residual retention obligation. 5) COMPLIANCE CONSIDERATIONS: Data mapping exercises should account for the distinction between personally identified data subject to deletion and de-identified model training data that may persist beyond a deletion request. User-facing communications about deletion rights should accurately reflect the de-identification carve-out to avoid creating expectations that cannot be technically fulfilled. Compliance teams should verify that the 30-day deletion timeline and exception categories satisfy applicable state statutory requirements.
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This provision establishes a 30-day deletion timeline with multiple categorical exceptions, and separately acknowledges that content already de-identified and incorporated into model training datasets is not subject to the deletion mechanism, which is a practical limitation on the scope of the deletion right for users who have not opted out of model training.
The agreement establishes a 30-day timeline for deletion of personal data following a user request, subject to exceptions for legal requirements, fraud and abuse, security, and financial record-keeping. Content that has already been de-identified and disassociated from a user account for model training purposes is stated to fall outside the scope of the deletion mechanism.
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