OpenAI may share your personal data with law enforcement or government authorities if it believes this is required by law or necessary to protect safety, prevent fraud, or enforce its terms.
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
The clause establishes OpenAI's authority to share user personal data with external parties in specified circumstances without prior user notification or consent, creating an operational framework for data disclosure outside normal service provision.
Interpretive note: The 'good faith belief' standard for disclosure to private parties, as distinct from mandatory legal process, is ambiguous regarding the threshold required before disclosure would occur.
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.
View change record →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.
View change record →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 →Sensitive information you share in conversations with OpenAI could be disclosed to law enforcement agencies or private parties if OpenAI determines in good faith that disclosure is necessary, which may occur without prior notice to you.
How other platforms handle this
We will share individual user information with companies, organizations or individuals outside of Google if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable govern...
By issuing a chargeback or refund request for Premium subscriptions paid for through a third party, you agree to allow Telegram to release necessary data to that third party regarding your account status and Telegram Premium purchases.
We may disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
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"We may disclose your Personal Data to law enforcement, government authorities, or private parties if we believe in good faith that such disclosure is necessary to: comply with applicable law or legal process, including to respond to subpoenas, search warrants, or court orders; protect the rights, property, or safety of OpenAI, our users, or others; detect, prevent, or address fraud, security, or technical issues; or enforce our terms of service or other agreements.— Excerpt from OpenAI's OpenAI Privacy Policy
(1) REGULATORY LANDSCAPE: This provision implicates the Electronic Communications Privacy Act (ECPA) and applicable state wiretap and stored communications laws in the US, as well as analogous frameworks in other jurisdictions. GDPR Article 6(1)(c) permits processing necessary for compliance with a legal obligation, which can cover mandatory disclosures, but voluntary disclosures require a separate legal basis. The breadth of the 'good faith belief' standard for voluntary disclosure (beyond mandatory legal process) may warrant scrutiny. (2) GOVERNANCE EXPOSURE: Medium. The 'good faith' standard for disclosure to 'private parties' in addition to law enforcement is broader than many comparable policies, which typically limit voluntary disclosure to law enforcement only. Disclosure to private parties for fraud or safety purposes without a legal requirement could raise questions about adequacy of threshold standards. (3) JURISDICTION FLAGS: EEA and UK users are protected by GDPR restrictions on law enforcement disclosures to non-EU authorities; disclosures to US law enforcement by an EU-established entity may require compliance with GDPR Chapter V transfer provisions. US users have fewer formal protections against voluntary law enforcement disclosures absent a specific statutory prohibition. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers handling sensitive or regulated data (healthcare, legal, financial) should assess whether submission of that data to OpenAI creates risks of unanticipated law enforcement disclosure and whether their acceptable use policies address this. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm whether OpenAI publishes a transparency report disclosing the volume of law enforcement requests received; assess whether the 'private parties' disclosure category is consistent with applicable law; and evaluate whether client confidentiality or professional privilege obligations restrict submission of certain data to OpenAI.
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The clause establishes OpenAI's authority to share user personal data with external parties in specified circumstances without prior user notification or consent, creating an operational framework for data disclosure outside normal service provision.
Sensitive information you share in conversations with OpenAI could be disclosed to law enforcement agencies or private parties if OpenAI determines in good faith that disclosure is necessary, which may occur without prior notice to you.
ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.