Provision record
OpenAI · OpenAI Sub-Processor List · View original document ↗

Microsoft cloud infrastructure processes customer data

Medium confidence Common · 281 of 343 platforms
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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)

Generated by a model from the captured document; not read by a person

Customer data processed through Microsoft's cloud infrastructure may be handled in any of 22 countries, each with different data protection regimes, significantly broadening the geographic scope of data exposure.

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Interpretive note: The excerpt does not specify which OpenAI services use Microsoft cloud infrastructure or which categories of customer data are affected. Country list is taken as stated but the full service scope is not determinable from the excerpt alone.

Consumer impact (what this means for users)

Generated by a model from the captured document; not read by a person

Your data processed through OpenAI's Microsoft cloud infrastructure may be handled in any of the 22 listed countries.

How other platforms handle this

Kling AI

The Company collect and process personal information in [Singapore, Malaysia] for the purpose of providing the services.

TikTok Ads

If you send us, or enable us to collect, Business Products Data...you agree to the Business Products (Data) Terms.

ActiveCampaign

If any portion of ActiveCampaign is sold, Contact Data may be part of the business assets we transfer. Contact Data also may be disclosed if ActiveCampaign is considering or completes the financing, securitization, insuring, sale, assignment or other transfer...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Microsoft Corporation ... 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 United States Cloud infrastructure

Excerpt from OpenAI's Sub-Processor List

Provision details

Document information
Document
OpenAI Sub-Processor List
Entity
OpenAI
Date stated by the document
Oct. 14, 2026
As printed in OpenAI’s text (version CA-V-007534), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
July 6, 2026
Text quoted from version
CA-V-005774, captured Aug. 14, 2026
Record ID
CA-P-069948
Document ID
CA-D-000928
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-005774)
2007f77524532432cd3b5bebbd4a66ca73131eca6a09f65aa148e7ccf545cb78
Analysis generated
July 6, 2026 23:01 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-005774, captured Aug. 14, 2026 (checked Oct. 5, 2026)
Not the current version. The document's current version is CA-V-007534, captured Oct. 15, 2026; this clause has not been re-checked against it.
Citation Record
Entity: OpenAI
Document: OpenAI Sub-Processor List
Record ID: CA-P-069948
Version: CA-V-005774
Captured: 2026-08-14 00:07:28 UTC
SHA-256: 2007f77524532432…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069948/microsoft-cloud-infrastructure-processes-customer-data/
Accessed: Oct. 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Microsoft cloud infrastructure processes customer data clause do?

Customer data processed through Microsoft's cloud infrastructure may be handled in any of 22 countries, each with different data protection regimes, significantly broadening the geographic scope of data exposure.

How does this clause affect you?

Your data processed through OpenAI's Microsoft cloud infrastructure may be handled in any of the 22 listed countries.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 281 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.