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The policy establishes that users may submit data access, correction, deletion, and portability requests through privacy.openai.com or dsar@openai.com, subject to credential verification, and states that requests from individuals whose identity cannot be verified will not be honored.
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 provision establishes the procedural requirements for exercising statutory privacy rights, including the verification requirement that may limit the ability of users without accounts or whose identity cannot be confirmed to exercise deletion or access rights, and provides specific contact channels for rights requests and appeals.
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 →The agreement establishes that users must verify their credentials to submit data access, correction, or deletion requests, and that OpenAI will not honor requests from individuals whose identity cannot be verified. Authorized agent requests may be submitted to dsar@openai.com with signed written permission, and appeal rights for denied requests are available through the same address.
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"You can exercise some of these rights through your OpenAI account using the tools described in the Data controls section, or you can submit your request through privacy.openai.com or to dsar@openai.com. You can contact our data protection officer at dpo@openai.com. In order to protect your Personal Data from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification. If we cannot verify your identity, we will not be able to honor your request.Excerpt from OpenAI's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages CCPA and CPRA requirements regarding the processing of consumer rights requests, including verification procedures, response timelines, and authorized agent procedures, enforced by the California Privacy Protection Agency. Parallel requirements exist under other state comprehensive privacy statutes. GDPR Article 12 requirements regarding the facilitation of data subject rights without excessive difficulty are engaged for EEA users under the separate policy. The policy's statement that unverified requests will not be honored is consistent with CCPA statutory language permitting reasonable verification, but the specific verification procedures are not detailed. 2) GOVERNANCE EXPOSURE: Low to Medium. The provision establishes standard rights request infrastructure including a dedicated email address, privacy portal, and DPO contact. The authorized agent procedure requiring signed written permission and independent identity verification is consistent with CCPA regulatory requirements. The absence of stated response timelines in the policy text may require compliance teams to confirm that internal procedures meet applicable statutory deadlines. 3) JURISDICTION FLAGS: California CPRA and CPRA regulations specify response timelines and authorized agent procedures that must be followed; the policy's general language should be evaluated against those specific requirements. Other states with enacted privacy statutes have varying response timeline and agent authorization requirements. EU and UK users have rights under GDPR that are addressed in the separate policy. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers whose employees submit individual rights requests should confirm through customer agreements whether the consumer-facing rights request procedure or a separate enterprise procedure applies. Sub-processors receiving data on behalf of OpenAI should have contractual obligations to support rights request fulfillment. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that internal rights request procedures meet applicable statutory response timelines not specified in the policy text. The DPO contact at dpo@openai.com should be noted for EU-related escalations. Appeal procedures through dsar@openai.com should be integrated into consumer-facing communications to ensure users are aware of this option.
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This provision establishes the procedural requirements for exercising statutory privacy rights, including the verification requirement that may limit the ability of users without accounts or whose identity cannot be confirmed to exercise deletion or access rights, and provides specific contact channels for rights requests and appeals.
The agreement establishes that users must verify their credentials to submit data access, correction, or deletion requests, and that OpenAI will not honor requests from individuals whose identity cannot be verified. Authorized agent requests may be submitted to dsar@openai.com with signed written permission, and appeal rights for denied requests are available through the same address.
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