31 Total
10 High severity
17 Medium severity
4 Low severity

Key Facts

Who does OpenAI share customer data with for moderation of content as part of Customer support?
OpenAI shares customer data with Accenture International Limited for moderation of content as part of Customer support for the API, ChatGPT Business, ChatGPT Enterprise, and Edu services, with processing in the United States, Canada, and Philippines.
Who does OpenAI use as a platform for content moderation?
OpenAI uses Cinder Technologies, Inc. as a platform for content moderation for the API and as a platform for moderation of GPTs for ChatGPT Enterprise, Edu, and ChatGPT Business, with processing in the United States, but this arrangement excludes customers using Zero Data Retention.
To what extent does OpenAI process Customer Data in the course of Customer Support?
OpenAI processes Customer Data in the course of Customer Support only to the extent the Customer explicitly elects to share such data in the course of the support case.
Who does OpenAI use to provide cloud infrastructure processing?
OpenAI uses Microsoft Corporation to provide cloud infrastructure processing across a listed set of countries including Australia, Brazil, Canada, France, Germany, India, Indonesia, Ireland, Italy, Japan, Mexico, Netherlands, Norway, Poland, Singapore, South Africa, South Korea, Spain, Sweden, Switzerland, United Arab Emirates, United Kingdom, and United States.
What countries are included in the cloud infrastructure processing that OpenAI uses Microsoft Corporation to provide?
OpenAI uses Microsoft Corporation to provide cloud infrastructure processing across a listed set of countries including Australia, Brazil, Canada, France, Germany, India, Indonesia, Ireland, Italy, Japan, Mexico, Netherlands, Norway, Poland, Singapore, South Africa, South Korea, Spain, Sweden, Switzerland, United Arab Emirates, United Kingdom, and United States.
With whom may OpenAI share samples of Customer Content flagged by its models?
OpenAI may share samples of Customer Content flagged by its models as violating OpenAI's policies with relevant sub-processors to assist OpenAI in its review.
May OpenAI conduct moderation of GPTs published to the public?
OpenAI may conduct moderation of GPTs published to the public if OpenAI determines the GPT may violate its policies.
Who does OpenAI use for data warehousing?
OpenAI uses Snowflake, Inc. for data warehousing with processing in the United States, except where Zero Data Retention is used.
What does OpenAI use as the valid transfer mechanism for data transfers among its affiliates?
OpenAI uses Standard Contractual Clauses as the valid transfer mechanism for data transfers among its affiliates.
For what period do OpenAI's sub-processors retain samples of flagged content?
OpenAI's sub-processors retain samples of flagged content only for the period of review, and only process that content to assist OpenAI in its review.
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Summary

This document lists the companies OpenAI shares your data with, what those companies do with it, and where in the world they process it. Your data may be handled by cloud providers and moderation vendors across more than 20 countries depending on which OpenAI service you use. Customers with Zero Data Retention status are excluded from certain sub-processor arrangements, such as data warehousing with Snowflake and content moderation via Cinder Technologies.

Analysis

This document establishes OpenAI's sub-processor arrangements, identifying the third-party entities that process customer data on OpenAI's behalf, the purposes for which they process it, and the geographic locations of that processing. It sets out data-sharing relationships with Microsoft Corporation (cloud infrastructure across 22 countries), Amazon Web Services (cloud infrastructure in the United States), Snowflake, Inc. (data warehousing in the United States), Accenture International Limited (content moderation and customer support across the United States, Canada, and Philippines), Cinder Technologies, Inc. (content moderation in the United States), and TaskUs, LLC (customer support and content moderation in the Philippines). The document limits customer support data processing to data the customer explicitly shares in a support interaction, restricts sub-processor retention of flagged content to the review period and review purpose only, and carves out Zero Data Retention customers from certain sub-processor arrangements. Standard Contractual Clauses are identified as the transfer mechanism for intra-affiliate data transfers.

What this means for you

As an individual user, your content may be shared with third-party sub-processors for moderation and customer support purposes, and those sub-processors may hold samples of flagged content for the duration of a policy review. During customer support, OpenAI processes only the data you explicitly choose to share in that support interaction. If your content is flagged as a potential policy violation, samples may be shared with relevant sub-processors, who retain them only for the review period. If you are a customer with Zero Data Retention status, your data is excluded from the Snowflake data warehousing and Cinder Technologies moderation arrangements.

Institutional Analysis
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Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.

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Featured, Medium severity

Complete Provision Index

Every distinct legal provision identified in this document. Featured provisions appear above with analysis.

31 provisions
12 featured
6 clause types
10 high severity
Data Sharing 26 6 high
Show all 26 data sharing provisions
Platform Discretion 1 1 high
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Mapped Governance Frameworks

BIPA
Illinois, USA
View official text ↗
California AB 2013 AI Training Data Transparency
US-CA
View official text ↗
CCPA/CPRA
California, USA
View official text ↗
Connecticut Data Privacy Act Amendments
US-CT
View official text ↗
CAN-SPAM
United States Federal
View official text ↗
DMCA
United States Federal
View official text ↗
DSA
European Union
View official text ↗
FTC Act Section 5
United States Federal
View official text ↗
GDPR
European Union
View official text ↗
Indiana Consumer Data Protection Act
US-IN
View official text ↗
Kentucky Consumer Data Protection Act
US-KY
View official text ↗
UK GDPR
United Kingdom
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗

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Archival ProvenanceSource & Archival Record
Last Captured August 14, 2026 00:07 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000928
Version ID CA-V-005774
SHA-256 851bb96fb639273308d1511cc837e6b10491fab7bfd212ea00f7ebd77794717d
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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