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

Post-Deletion Data Retention

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Document Record

What it is

The policy establishes that user-deleted personal data is removed within 30 days, subject to exceptions for legal obligations, fraud prevention, security, financial recordkeeping, policy violations, and content already de-identified for model training. Data subject to these exceptions may be retained beyond the user-requested deletion date.

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 defines the practical limits of the user deletion right. The de-identification carve-out is particularly significant: content that has already been de-identified and disassociated from an account for model training purposes may not be removed following a deletion request, which constrains the operational scope of deletion rights for users who have not previously opted out of training data use.

Interpretive note: The policy does not specify maximum retention durations for each exception category, and the enforceability of the de-identification carve-out as a complete defense to deletion requests under various state privacy laws is subject to regulatory interpretation.

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

Consumer impact (what this means for users)

Under this clause, a deletion request will result in removal of personal data within 30 days in most cases, but data retained for fraud, legal, security, or financial recordkeeping purposes may remain beyond that window. Content already de-identified for model training before the deletion request is processed may not be deleted under the terms as stated.

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
    Submit a data deletion request at privacy.openai.com or by emailing dsar@openai.com. Identity verification may be required before the request is processed.

Cross-platform context

See how other platforms handle Post-Deletion Data Retention and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
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... 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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The right to deletion is established under CCPA and CPRA for California residents, with enumerated exceptions that generally align with those cited in this policy.

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

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-013567
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-013567
Captured: 2026-07-09 03:28:49 UTC
SHA-256: c0c49f013e1bb2dd…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/provision/CA-P-013567/post-deletion-data-retention/
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 Post-Deletion Data Retention clause do?

This provision defines the practical limits of the user deletion right. The de-identification carve-out is particularly significant: content that has already been de-identified and disassociated from an account for model training purposes may not be removed following a deletion request, which constrains the operational scope of deletion rights for users who have not previously opted out of training data use.

How does this clause affect you?

Under this clause, a deletion request will result in removal of personal data within 30 days in most cases, but data retained for fraud, legal, security, or financial recordkeeping purposes may remain beyond that window. Content already de-identified for model training before the deletion request is processed may not be deleted under the terms as stated.

Is ConductAtlas affiliated with OpenAI?

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