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

GDPR Data Subject Rights for EEA and UK Users

Medium severity High confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

If you live in the EU or UK, you have formal legal rights to see, correct, delete, and export your OpenAI personal data, and to object to how it is processed.

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)

The clause operationalizes statutory obligations under GDPR and UK data protection law by explicitly enumerating the mechanisms through which EEA and UK users may exercise their rights against the controller, thereby establishing OpenAI's procedural framework for handling data subject requests.

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 →

Consumer impact (what this means for users)

EEA and UK users can submit requests to access or delete their OpenAI data by contacting dsar@openai.com, with OpenAI obligated under GDPR to respond within one month of the request.

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.
  • Delete Your Data
    Send an email to dsar@openai.com requesting access, correction, deletion, or portability of your personal data. Include your account email address and specify the nature of your request; OpenAI is required to respond within one month under GDPR.

How other platforms handle this

Roblox Medium

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...

Google Cloud Medium

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.

ClickUp Medium

If you are an end user in a Workspace not owned by you and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization who owns your ClickUp Workspace.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
If you are located in the EEA or UK, you have the following rights under applicable data protection law: Access: You can request a copy of the personal data we hold about you. Correction: You can ask us to correct inaccurate data. Deletion: You can ask us to delete your personal data. Portability: You can request a machine-readable copy of your personal data. Restriction: You can ask us to restrict how we process your personal data. Objection: You can object to our processing of your personal data. Withdrawing consent: You can withdraw your consent at any time where we rely on consent as our legal basis.

Excerpt from OpenAI's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision reflects obligations under GDPR Articles 15-22 and the UK GDPR.

Insight

Unlock the full institutional analysis

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

Applicable agencies

  • 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

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009766
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9fedd919cc6d99e951ea6b8c198d3ded6d0673342d8c265778e44a35720b9b49
Analysis generated
May 10, 2026 22:24 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-009766
Captured: 2026-05-10 22:24:41 UTC
SHA-256: 9fedd919cc6d99e9…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/provision/CA-P-009766/gdpr-data-subject-rights-for-eea-and-uk-users/
Accessed: Sept. 20, 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 GDPR Data Subject Rights for EEA and UK Users clause do?

The clause operationalizes statutory obligations under GDPR and UK data protection law by explicitly enumerating the mechanisms through which EEA and UK users may exercise their rights against the controller, thereby establishing OpenAI's procedural framework for handling data subject requests.

How does this clause affect you?

EEA and UK users can submit requests to access or delete their OpenAI data by contacting dsar@openai.com, with OpenAI obligated under GDPR to respond within one month of the request.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenAI?

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