When a user connects their device contacts, OpenAI uploads the full address book to check which contacts use the service, and retains information about non-users to notify the uploading user if those contacts later register.
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 collection and processing of personal data belonging to individuals who have not created an OpenAI account and have not consented to data collection. The retention of non-user contact data for future notification purposes is an operational practice that has attracted regulatory attention in other platform contexts.
Interpretive note: The policy does not specify retention periods or deletion mechanisms for non-user contact data in the primary policy text; the linked help center article governs those details, which are outside this document.
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 →Under this clause, users who connect their device contacts allow OpenAI to upload and process the personal data of people who are not OpenAI users, and to retain that data until or unless those individuals sign up for the service. The agreement does not specify a retention limit for non-user contact data in this policy text.
Cross-platform context
See how other platforms handle Contact Data Upload and Non-User Data Collection and similar clauses.
Compare across platforms →"If you choose to connect your device contacts, we upload information from your device address books and check which of your contacts also use our Services. If any of your contacts aren't yet using our Services, we'll update you if they sign up for our Services later.Excerpt from OpenAI's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages state privacy laws that may extend protections to non-users whose data is collected by a service they do not use.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision authorizes collection and processing of personal data belonging to individuals who have not created an OpenAI account and have not consented to data collection. The retention of non-user contact data for future notification purposes is an operational practice that has attracted regulatory attention in other platform contexts.
Under this clause, users who connect their device contacts allow OpenAI to upload and process the personal data of people who are not OpenAI users, and to retain that data until or unless those individuals sign up for the service. The agreement does not specify a retention limit for non-user contact data in this policy text.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.