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 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 →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
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
Third-party apps use data from Gemini consistent with their own privacy policies and terms.
"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 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.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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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 288 platforms. See the full comparison.
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