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

Contact Data Upload for Non-Users

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Document Record

What it is

The policy states that when a user opts to connect device contacts, OpenAI uploads address book data including information about individuals who do not use OpenAI's services, retains that data, and uses it to notify the account holder if non-users subsequently 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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes collection and retention of personal data from individuals who have not agreed to OpenAI's terms or privacy policy, as the data subjects are third parties whose information appears in a user's device address book. This raises questions about the notice and consent basis for processing non-user personal data under applicable privacy frameworks.

⚠

Interpretive note: The full scope of how non-user contact data is retained and used is described in a referenced help center article not included in this document, creating uncertainty about the complete operational practice.

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 →

Consumer impact (what this means for users)

Under this provision, choosing to connect device contacts causes OpenAI to upload and retain address book data, including data about individuals who are not OpenAI users and who have not separately consented to this collection. The policy links to additional information about how uploaded contact information of non-users is used.

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
    If you have connected your device contacts and wish to request deletion of uploaded contact data, submit a data subject access or deletion request at privacy.openai.com or by emailing dsar@openai.com.

Cross-platform context

See how other platforms handle Contact Data Upload for Non-Users and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision implicates CCPA and CPRA to the extent non-user contacts are California residents whose personal data is collected without their direct consent.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • FTC
    The FTC has jurisdiction over data collection practices that may affect consumers who have not directly consented to data processing, including collection of non-user contact information.
    File a complaint →

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
Sept. 11, 2026
Last verified
Sept. 11, 2026
Record ID
CA-P-077391
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8ee232ad6c110b02c18d379ad054ed5a418f8064056cc5138741afff26158d34
Analysis generated
September 11, 2026 01:57 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-077391
Captured: 2026-09-11 01:57:58 UTC
SHA-256: 8ee232ad6c110b02…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/provision/CA-P-077391/contact-data-upload-for-non-users/
Accessed: Sept. 27, 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 Contact Data Upload for Non-Users clause do?

This provision authorizes collection and retention of personal data from individuals who have not agreed to OpenAI's terms or privacy policy, as the data subjects are third parties whose information appears in a user's device address book. This raises questions about the notice and consent basis for processing non-user personal data under applicable privacy frameworks.

How does this clause affect you?

Under this provision, choosing to connect device contacts causes OpenAI to upload and retain address book data, including data about individuals who are not OpenAI users and who have not separately consented to this collection. The policy links to additional information about how uploaded contact information of non-users is used.

Is ConductAtlas affiliated with OpenAI?

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