OpenAI · OpenAI Privacy Policy · View original document ↗

Disclosure to Third Parties and Service Providers

Medium severity Unique · 0 of 343 platforms
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Recent governance activity OpenAI recorded 32 documented changes in the last 30 days.
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Document Record

What it is

OpenAI shares your personal data with a wide range of outside companies for services like payments and marketing, and will hand over your data to government authorities when legally required.

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 the operational framework for data sharing across OpenAI's service delivery infrastructure and specifies conditions under which Personal Information may be disclosed to external parties and government entities. The clause delineates the categories of third parties with authorized access and the legal grounds for compelled disclosure.

Recent Activity

This document changed recently

Medium Jun 12, 2026

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.

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Medium Jun 9, 2026

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.

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Medium May 27, 2026

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 →

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 27, 2026
First Seen
Apr 27, 2026
Last Seen

Consumer impact (what this means for users)

Your personal data is shared with third-party service providers for marketing, analytics, payment processing, and other purposes, and may be disclosed to law enforcement or national security agencies without your knowledge or consent upon receipt of valid legal process.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share your Personal Information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also disclose your Personal Information to comply with applicable law or a valid legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

— Excerpt from OpenAI's OpenAI Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY FRAMEWORK: This provision implicates CCPA/CPRA §§1798.110, 1798.115 (disclosure of categories of third-party recipients); FTC Act Section 5 for adequate disclosure of data sharing; Electronic Communications Privacy Act (ECPA, 18 U.S.C. §2701 et seq.) and the Stored Communications Act (18 U.S.C. §2703) governing government access to stored communications; National Security Letter authority (18 U.S.C. §2709); and the Foreign Intelligence Surveillance Act (FISA, 50 U.S.C. §1801) for national security data requests. The FTC, DOJ, and relevant state AGs have enforcement jurisdiction. (2)

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces against inadequate disclosure of third-party data sharing under FTC Act Section 5 and has authority over commercial data broker and marketing data sharing practices.
    File a complaint →
  • State AG
    State AGs enforce CCPA/CPRA rights to know which third parties received personal information, and can bring actions for inadequate disclosure of data sharing practices.
    File a complaint →

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
April 27, 2026
Record ID
CA-P-003161
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8d0fc75b2591d6a033bfeb50a1e7b57bb62cb682a52fcbbd714621617a7525af
Analysis generated
April 27, 2026 09:30 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-003161
Captured: 2026-04-27 09:30:04 UTC
SHA-256: 8d0fc75b2591d6a0…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/disclosure-to-third-parties-and-service-providers/
Accessed: June 17, 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 Disclosure to Third Parties and Service Providers clause do?

This provision establishes the operational framework for data sharing across OpenAI's service delivery infrastructure and specifies conditions under which Personal Information may be disclosed to external parties and government entities. The clause delineates the categories of third parties with authorized access and the legal grounds for compelled disclosure.

How does this clause affect you?

Your personal data is shared with third-party service providers for marketing, analytics, payment processing, and other purposes, and may be disclosed to law enforcement or national security agencies without your knowledge or consent upon receipt of valid legal process.

Is ConductAtlas affiliated with OpenAI?

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