OpenAI states it shares personal information with advertising, analytics, and marketing partners, in addition to cloud and operational service providers.
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 authorizes sharing of personal data including identifiers, usage data, and behavioral data with advertising partners, which under CCPA may constitute a 'sale' or 'sharing' of personal information triggering opt-out rights for California residents.
Interpretive note: The policy does not enumerate specific advertising partners or the precise categories of data shared with each, making the full scope of this sharing difficult to assess from the document alone.
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 policy authorizes sharing of personal identifiers and usage data with advertising and marketing partners; California residents have the right to opt out of this sharing via the privacy request form at privacy.openai.com.
How other platforms handle this
We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.
to request that your data be transferred to a third party (data portability)
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.
"We may share personal information with third-party vendors and service providers that support our business, such as cloud services, analytics, customer support, payment processing, and marketing. We may share personal information with advertising and marketing partners to market our services and develop our business.Excerpt from OpenAI's Privacy Policy
REGULATORY LANDSCAPE: This provision engages CCPA and CPRA, under which sharing personal data with advertising partners for cross-context behavioral advertising purposes may qualify as a regulated 'share' requiring a Do Not Sell or Share opt-out …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision authorizes sharing of personal data including identifiers, usage data, and behavioral data with advertising partners, which under CCPA may constitute a 'sale' or 'sharing' of personal information triggering opt-out rights for California residents.
The policy authorizes sharing of personal identifiers and usage data with advertising and marketing partners; California residents have the right to opt out of this sharing via the privacy request form at privacy.openai.com.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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