OpenAI may share your personal data with a range of third parties including technology vendors, affiliated companies, and any buyer in a corporate sale or merger.
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 clause establishes the operational scope of data sharing beyond OpenAI's direct control, defining circumstances under which user data flows to external parties involved in service delivery, corporate operations, and organizational changes. It structures the authorization framework for data transfers that may occur during normal business operations or material corporate events.
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 →Your personal data including account information, conversation content, and usage data may be disclosed to vendors, affiliates, and acquirers, potentially reducing your practical control over who holds your information.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...
We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.
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"We may share your Personal Data with third parties in the following circumstances: Vendors and Service Providers: We share your Personal Data with vendors and service providers who perform services for us, such as hosting, infrastructure, analytics, payment processing, and customer support. Affiliates: We share your Personal Data with our affiliates for purposes consistent with this Privacy Policy. Business Transfers: If we are involved in a merger, acquisition, bankruptcy, or other transaction, your Personal Data may be transferred as part of that transaction.— Excerpt from OpenAI's OpenAI Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 13 and 14 (transparency obligations), Article 28 (processor agreements), and Article 46 (transfer mechanisms) for cross-border sharing. CCPA requires disclosure of categories of third parties with whom data is shared, which this provision partially satisfies. FTC Act Section 5 applies to representations about data sharing that are materially incomplete or misleading. (2) GOVERNANCE EXPOSURE: Medium. The policy discloses categories of recipients but does not name specific vendors or affiliates, which limits transparency and may create challenges for users seeking to exercise deletion or portability rights against downstream holders. Business transfer language is standard but creates successor liability questions regarding whether acquirers would be bound by this policy's commitments. (3) JURISDICTION FLAGS: EEA and UK users are entitled under GDPR to know the identity of recipients or categories of recipients; the categorical approach may require supplementation for full compliance. California users have CCPA rights to know and opt out of sale, though OpenAI does not characterize sharing as a 'sale.' (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise buyers should request a list of OpenAI's sub-processors and confirm that data processing agreements contain adequate representations, audit rights, and breach notification obligations consistent with GDPR Article 28. Business transfer provisions should be evaluated for whether they allow OpenAI to assign data processing obligations without user or customer notice. (5) COMPLIANCE CONSIDERATIONS: Legal teams should ensure that vendor contracts with OpenAI include appropriate data processing addenda, that sub-processor lists are monitored for changes, and that any corporate transaction notification obligations to data subjects are addressed in the event OpenAI undergoes a material ownership change.
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This clause establishes the operational scope of data sharing beyond OpenAI's direct control, defining circumstances under which user data flows to external parties involved in service delivery, corporate operations, and organizational changes. It structures the authorization framework for data transfers that may occur during normal business operations or material corporate events.
Your personal data including account information, conversation content, and usage data may be disclosed to vendors, affiliates, and acquirers, potentially reducing your practical control over who holds your information.
ConductAtlas has identified this type of provision across 4 platforms. See the full comparison.
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