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

Snowflake data warehousing excludes ZDR customers

High severity High confidence Explicit document language Common · 288 of 352 platforms

Key Facts

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.
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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

Tinder Medium

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...

Skillshare Medium

Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud

Squarespace Medium

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

See all platforms with this clause type →
▸ 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 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: Aug. 19, 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 288 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.