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

Snowflake data warehousing excludes ZDR customers

High severity High confidence Explicitdocumentlanguage Common · 290 of 352 platforms
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Recent governance activity OpenAI recorded 14 documented changes in the last 30 days.
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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)

Customer data is sent to Snowflake for warehousing unless the customer has Zero Data Retention, making ZDR status the operative factor in whether Snowflake processes a customer's data.

Consumer impact (what this means for users)

If you use OpenAI's API without Zero Data Retention, your data may be warehoused by Snowflake in the United States.

How other platforms handle this

Squarespace Medium

Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).

Lime Medium

if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services

Google Gemini Medium

Gemini Apps may share your precise location data with another Google service, like Google Maps, to fulfill your request.

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▸ View Original Clause Language DOCUMENT RECORD
"
Snowflake, Inc. API* ... United States Data warehousing ... * Except where Zero Data Retention (ZDR) is used

— Excerpt from OpenAI's OpenAI Sub-Processor List

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
OpenAI Sub-Processor List
Entity
OpenAI
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-069960
Document ID
CA-D-00928
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a031cf75d704b4e3de0cedb3ff0a622f189068f774fcde7f6f76c2a0b6251ac3
Analysis generated
July 6, 2026 23:01 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Sub-Processor List
Record ID: CA-P-069960
Captured: 2026-07-06 23:01:36 UTC
SHA-256: a031cf75d704b4e3…
URL: https://conductatlas.com/platform/openai/openai-sub-processor-list/provision/CA-P-069960/snowflake-data-warehousing-excludes-zdr-customers/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does OpenAI's Snowflake data warehousing excludes ZDR customers clause do?

Customer data is sent to Snowflake for warehousing unless the customer has Zero Data Retention, making ZDR status the operative factor in whether Snowflake processes a customer's data.

How does this clause affect you?

If you use OpenAI's API without Zero Data Retention, your data may be warehoused by Snowflake in the United States.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 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.