OpenAI · OpenAI Privacy Policy · View original document ↗

Third-Party Data Sharing

High severity Uncommon · 24 of 325 platforms
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Recent governance activity OpenAI recorded 11 documented changes in the last 30 days.
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Document Record

What it is

OpenAI shares your personal data with a range of outside companies for services like payments, cloud storage, and analytics, and can transfer all your data to a new owner if OpenAI is sold or restructured.

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 clause establishes the operational framework through which OpenAI discloses user personal information to external service providers necessary for platform operations and defines the circumstances under which such information may transfer between entities in corporate restructuring scenarios.

Recent Activity

This document changed recently

Medium May 14, 2026

The updated policy now explicitly states four privacy rights that apply depending on your location and subject to applicable exceptions: the right to know about and access your personal data in portable format, the right to request deletion, the right to correct inaccurate data, and the right to be free from retaliation for exercising these rights. Previously, the policy referenced these rights only through procedural language about how to submit requests. The explicit enumeration establishes clearer notice of what protections the policy recognizes. You can exercise these rights by submitting a request through privacy.openai.com or dsar@openai.com.

View change record →
Medium May 11, 2026

The updated policy now explicitly discloses that OpenAI receives information from advertisers and data partners, including details about purchases you make, and uses this data to personalize ads shown to Free and Go users. Previously, the policy referenced ad effectiveness measurement without disclosing the specific source (advertiser data) or the personalization component. Under the revised terms, Free and Go users can use advertising controls in account settings to control what data OpenAI uses to personalize ads. You can access these controls through your OpenAI account settings to adjust ad personalization.

View change record →
Medium May 5, 2026

The updated policy no longer explicitly states that OpenAI receives information from advertisers and other data partners for ad measurement and improvement, nor does it mention that users can control what data is used to personalize ads shown on the service. The revised terms now establish a broader direct marketing authority, stating the company may promote products and services to users through direct marketing and on third-party properties to assess effectiveness, subject to user choices and controls. The policy adds a reference to a Korea Addendum for Korean users. You can review the linked resources to understand what choices and controls remain available.

View change record →

Consumer impact (what this means for users)

Your personal data, including your ChatGPT conversation history, can be shared with numerous third-party vendors and may be transferred to a new owner in a corporate transaction without your specific consent, giving you limited control over who ultimately holds your information.

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
    Submit a data deletion request through OpenAI's privacy portal to request removal of your personal data before any potential corporate transfer.

How other platforms handle this

Coinbase Medium

We may share personal information with third-party service providers and partners who support our business operations, including identity verification providers, payment processors, analytics providers, marketing partners, and blockchain analytics companies.

Windsurf Medium

You may elect to use or integrate platforms, add-ons, services, or products not provided by Exafunction ("Third-Party Platforms") (e.g. User IDE's, Web Search, MCP Servers) subject to your agreement with the relevant provider and not this Agreement. We do not control nor shall we have liability for ...

Spotify Medium

We receive some of the data mentioned above from third parties... If you connect your Spotify account to a third party application, service or device, we may collect and use information from them. This collection is to make the integration possible... We work with technical service partners that giv...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share your personal information with third parties in the following circumstances: Vendors and service providers: We share information with third-party vendors and service providers that perform services on our behalf, such as payment processing, security, cloud infrastructure, customer support, data analytics, and other services. Business transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider, your information may be transferred as part of such a transaction.

— Excerpt from OpenAI's OpenAI Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY FRAMEWORK: GDPR Art. 28 requires data processing agreements with all processors; Art. 44-46 governs cross-border transfers. CCPA/CPRA §1798.140 defines 'sale' and 'sharing' broadly — transfer of data as part of a business asset sale may trigger disclosure obligations. FTC Act Section 5 applies to material changes in data handling post-acquisition. (2)

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC oversees unfair or deceptive practices related to post-acquisition data use and third-party data sharing under FTC Act Section 5.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
March 6, 2026
Last verified
April 10, 2026
Record ID
CA-P-002004
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
90ad72975ac0d9d86d724561a29d464c061ec09345abf2fde0eccd43d6205bcf
Analysis generated
March 6, 2026 20:23 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-002004
Captured: 2026-03-06 20:23:45 UTC
SHA-256: 90ad72975ac0d9d8…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/third-party-data-sharing/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Third-Party Data Sharing clause do?

This clause establishes the operational framework through which OpenAI discloses user personal information to external service providers necessary for platform operations and defines the circumstances under which such information may transfer between entities in corporate restructuring scenarios.

How does this clause affect you?

Your personal data, including your ChatGPT conversation history, can be shared with numerous third-party vendors and may be transferred to a new owner in a corporate transaction without your specific consent, giving you limited control over who ultimately holds your information.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 24 platforms. See the full comparison.

Is ConductAtlas affiliated with OpenAI?

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