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
disclosure is required by a third-party to complete a transaction initiated by the user
Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).
Monitoring
OpenAI has changed this document before.
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"Cinder Technologies, Inc. API* ... United States API & ChatGPT Business: Platform for content moderation ChatGPT Enterprise, Edu & ChatGPT Business: Platform for moderation of GPTs— Excerpt from OpenAI's OpenAI Sub-Processor List
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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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 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.