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The policy authorizes use of Free and Go user data to personalize in-service advertising and to measure ad effectiveness, including receipt of purchase data from third-party advertisers to assist in that measurement. Users can adjust advertising personalization through account settings.
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 establishes that OpenAI receives purchase-level data from third-party advertisers about Free and Go users, which is used for ad measurement and personalization. The policy discloses this as a form of cross-context behavioral advertising or targeted advertising under US state privacy laws, with an opt-out mechanism available in account settings.
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 these terms, Free and Go users' in-service experience includes advertising personalized using their usage data and potentially purchase data received from third-party advertisers. The agreement discloses this practice as cross-context behavioral advertising under applicable state privacy laws, and provides an opt-out via account settings or the Global Privacy Control mechanism.
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"For Free and Go users, to personalize the ads you see on our Services (subject to your settings), and to measure the effectiveness of ads shown on our Services. Learn more about ads on our services... We may receive information from advertisers and other data partners, which we use for purposes including to help us measure and improve the effectiveness of ads shown to Free and Go users on our Services. For example, we could receive information about purchases you make from these advertisers.Excerpt from OpenAI's Privacy Policy
1) REGULATORY LANDSCAPE: The policy explicitly identifies this practice as 'targeted advertising' or sharing for 'cross-context behavioral advertising' under US state privacy laws, engaging CCPA and CPRA opt-out requirements. California's CPRA requires a clear opt-out for cross-context behavioral advertising. Colorado, Connecticut, Virginia, and other comprehensive state privacy statutes have analogous requirements. The FTC has active interest in data broker and advertising data practices. The policy states OpenAI does not 'sell' personal data, but the cross-context behavioral advertising disclosure is the relevant category under modern state privacy law frameworks. 2) GOVERNANCE EXPOSURE: Medium. The receipt of third-party advertiser purchase data is a significant operational disclosure. The policy does not specify which advertisers provide this data, the volume or specificity of purchase data received, or how it is combined with on-platform data. This creates due diligence questions for compliance teams assessing the breadth of the advertising data ecosystem. 3) JURISDICTION FLAGS: California residents have explicit opt-out rights under CPRA for cross-context behavioral advertising. Users in states with comprehensive privacy statutes have analogous rights. The provision states that these advertising practices do not apply to users known to be under 18, which aligns with COPPA and state minor privacy protections. 4) CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying ChatGPT in consumer-facing contexts should assess whether employee or customer use of Free tier accounts creates advertising data flows that interact with internal data governance commitments. Marketing and advertising partners who provide purchase data to OpenAI under this provision should review whether their data sharing agreements adequately disclose downstream use. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism for cross-context behavioral advertising meets the prominence and accessibility standards of CPRA and equivalent state laws. The Global Privacy Control opt-out mechanism is specifically referenced, which aligns with California regulatory guidance. Data mapping should capture the inbound advertiser data flow as a distinct processing activity.
This provision establishes that OpenAI receives purchase-level data from third-party advertisers about Free and Go users, which is used for ad measurement and personalization. The policy discloses this as a form of cross-context behavioral advertising or targeted advertising under US state privacy laws, with an opt-out mechanism available in account settings.
Under these terms, Free and Go users' in-service experience includes advertising personalized using their usage data and potentially purchase data received from third-party advertisers. The agreement discloses this practice as cross-context behavioral advertising under applicable state privacy laws, and provides an opt-out via account settings or the Global Privacy Control mechanism.
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