OpenAI may collect sensitive personal information including health details, financial information, and other sensitive content that you type into ChatGPT conversations.
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
The clause establishes the scope of data collection OpenAI is authorized to obtain from users. By defining collection mechanisms and categories of sensitive information, the provision creates the operational basis for how user data flows into OpenAI's systems and what categories of information the organization processes.
The updated policy removes language describing how OpenAI uses advertiser and data partner information to personalize ads and measure ad effectiveness. The policy also removes the specific mechanism Free and Go users previously had to control ad personalization through account settings. In exchange, the policy adds explicit authorization for OpenAI to identify which of a user's contacts use OpenAI services and to monitor all content submitted on the platform for fraud and misuse detection. The authorization to monitor content and identify contacts now appears in the main policy purposes section rather than in supplementary documentation. You can review the Korea Addendum if you are located in South Korea to understand region-specific privacy rules.
View change record →The updated policy removes language that previously described ad personalization controls available to Free and Go users through account settings, though the policy continues to authorize OpenAI to personalize ads and measure their effectiveness for these user tiers. Previously, the policy explicitly stated that 'For Free and Go users, you can use the advertising controls in your account settings to control what data we use to personalize the ads we show you on our Services.' This language is no longer present in the updated version. The policy still lists ad personalization as an authorized use of personal data for Free and Go users, but no longer explicitly describes how users can access controls to manage this practice. You should verify whether advertising controls remain functional in your OpenAI account settings, as the policy no longer explicitly references them.
View change record →The updated policy removes specific language stating that OpenAI receives advertiser data to personalize ads shown to Free and Go users. It also removes reference to account-level advertising controls previously described in account settings. These removals are replaced with broader language authorizing OpenAI to promote products through direct marketing and third-party properties, subject to choices and controls, but the terms no longer explicitly describe what advertiser data is collected, from whom, or how to manage it at the account level. The policy now requires users to follow a 'learn more' link to understand ad personalization controls, rather than documenting those controls directly in the privacy policy.
View change record →Sensitive personal information including health conditions, financial situations, and other private details shared in ChatGPT conversations is collected, retained, and potentially used for AI model training, with human reviewers at OpenAI having access to conversation content for safety and quality purposes.
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"We collect information you provide directly to us, such as when you create an account, submit or post content through our Services, communicate with us, or otherwise interact with us. The types of information we may collect include your name, email address, account credentials, payment card information, and any other information you choose to provide. Depending on your use of our Services, this may include health or medical information, information about your financial situation, or other sensitive details you share in conversations.— Excerpt from OpenAI's OpenAI Privacy Policy
(1) REGULATORY FRAMEWORK: This provision implicates CCPA/CPRA Cal. Civ. Code §1798.121 (right to limit use of sensitive personal information, defined in §1798.140(ae)); state biometric privacy laws including Illinois BIPA (740 ILCS 14) if voice data is processed; HIPAA 45 CFR §164.502 if any conversations contain PHI and OpenAI qualifies as a business associate; FTC Act Section 5 for inadequate disclosure of sensitive data collection practices; and potentially FERPA (20 U.S.C. §1232g) if students share educational records. The CPPA, FTC, HHS OCR, and state AGs are relevant enforcement authorities. (2)
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The clause establishes the scope of data collection OpenAI is authorized to obtain from users. By defining collection mechanisms and categories of sensitive information, the provision creates the operational basis for how user data flows into OpenAI's systems and what categories of information the organization processes.
Sensitive personal information including health conditions, financial situations, and other private details shared in ChatGPT conversations is collected, retained, and potentially used for AI model training, with human reviewers at OpenAI having access to conversation content for safety and quality purposes.
ConductAtlas has identified this type of provision across 8 platforms. See the full comparison.
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