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

User Content Used to Train AI Models

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Document Record

What it is

The policy states that user-submitted content, including prompts, files, images, audio, and video, may be used by OpenAI to train the AI models that power its Services, subject to a user-controlled opt-out.

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 establishes a default opt-in posture for AI model training using personal user content, requiring users to affirmatively opt out rather than affirmatively consent; in jurisdictions where secondary use of personal data for AI training requires opt-in consent, this posture may require evaluation under applicable law.

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 →

Clause Stability Stable

0
Changes
6
Months Monitored
Jul 17, 2026
First Seen
Jul 17, 2026
Last Seen

Change history

modified Jul 17, 2026

No material change in text; only provision name simplified from 'AI Model Training Using User Content' to 'User Content Used to Train AI Models'.

View full change record →

Consumer impact (what this means for users)

Under this provision, user-submitted content including prompts and uploaded files is used to train OpenAI's AI models unless the user opts out through account settings or privacy.openai.com. The policy also notes that content which has already been de-identified and disassociated from an account prior to a deletion request may not be removed from training datasets.

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.
  • Opt Out of Arbitration
    Log in to your OpenAI account and navigate to privacy.openai.com, or access account settings and locate the data controls section to toggle off the option allowing your content to be used for model training.

Cross-platform context

See how other platforms handle User Content Used to Train AI Models and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
As noted above, we may use Content you provide us to improve our Services, for example to train the models that power ChatGPT. Read our instructions on how you can opt out of our use of your Content to train our models.

Excerpt from OpenAI's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision engages GDPR Article 6 lawful basis requirements and Article 9 for any special category data that may appear in user prompts, enforced by EU data protection authorities including the Irish …

Insight

Unlock the full institutional analysis

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

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
OpenAI Privacy Policy
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
July 17, 2026
Last verified
July 17, 2026
Record ID
CA-P-076304
Document ID
CA-D-00010
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fa1fc773029acbb2f7359fc6c446a060a24dfbd48cd5a4f96386e6d01097944b
Analysis generated
July 17, 2026 01:40 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Privacy Policy
Record ID: CA-P-076304
Captured: 2026-07-17 01:40:05 UTC
SHA-256: fa1fc773029acbb2…
URL: https://conductatlas.com/platform/openai/openai-privacy-policy/provision/CA-P-076304/user-content-used-to-train-ai-models/
Accessed: Sept. 8, 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 User Content Used to Train AI Models clause do?

This provision establishes a default opt-in posture for AI model training using personal user content, requiring users to affirmatively opt out rather than affirmatively consent; in jurisdictions where secondary use of personal data for AI training requires opt-in consent, this posture may require evaluation under applicable law.

How does this clause affect you?

Under this provision, user-submitted content including prompts and uploaded files is used to train OpenAI's AI models unless the user opts out through account settings or privacy.openai.com. The policy also notes that content which has already been de-identified and disassociated from an account prior to a deletion request may not be removed from training datasets.

Is ConductAtlas affiliated with OpenAI?

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