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
Customer data is routed to Cinder Technologies for moderation, but Zero Data Retention customers are carved out, meaning their data does not pass through this sub-processor.
Interpretive note: The asterisk notation in the excerpt suggests the ZDR exclusion applies to the API designation; whether it also applies to the ChatGPT Enterprise/Edu/Business scopes is not entirely clear from the minimal excerpt.
If you use the API or ChatGPT Enterprise, Edu, or Business services without Zero Data Retention, your content may be processed by Cinder Technologies in the United States for moderation.
How other platforms handle this
Perplexity may process the following data if AI features are enabled: Customer Content and context
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
"Cinder Technologies, Inc. API* ... United States API & ChatGPT Business: Platform for content moderation ChatGPT Enterprise, Edu & ChatGPT Business: Platform for moderation of GPTsExcerpt from OpenAI's Sub-Processor List
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Customer data is routed to Cinder Technologies for moderation, but Zero Data Retention customers are carved out, meaning their data does not pass through this sub-processor.
If you use the API or ChatGPT Enterprise, Edu, or Business services without Zero Data Retention, your content may be processed by Cinder Technologies in the United States for moderation.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.