Provision record
OpenAI · OpenAI Terms of Use · View original document ↗

Model Training Data Use

High severity Common · 217 of 352 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)

This provision establishes differentiated data practices across user tiers, requiring explicit opt-in consent for certain user categories before their content enters model training workflows, while establishing an opt-out mechanism for free users. The clause creates distinct operational pathways for content use depending on account type and user election.

Clause Stability Stable

0
Changes
5
Months Monitored
Apr 27, 2026
First Seen
Apr 27, 2026
Last Seen
This clause type exists across 921 other provisions on other platforms.

Consumer impact (what this means for users)

Free ChatGPT users operate under terms that permit model training use by default, but allow them to disable this through settings modifications. API users and paid non-API users operate under terms that exclude their content from model training unless they affirmatively elect inclusion through opt-in procedures.

How other platforms handle this

GitHub Medium

We generate new information from other data we collect to derive likely preferences or other characteristics. For instance, we infer your general geographic location based on your IP address.

Microsoft Medium

Microsoft also emphasizes the importance of validating AI models responsibly to enhance fairness and alignment with reality.

Google Cloud Medium

To achieve these processing purposes, we use algorithms to recognize patterns in Service Data, manual review of Service Data (such as when you interact directly with our billing or support teams)...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We use your content to provide, maintain, and improve our Services and to develop new programs and services. We will not use content from ChatGPT's memory feature or from API users (unless they opt in) or from paid non-API users (unless they opt in) to train our models. If you are a free user of ChatGPT, you can opt out of model training in your settings.

Excerpt from OpenAI's Terms of Use

Applicable regulations

EU AI Act
European Union
California AB 2013 AI Training Data Transparency
US-CA
Colorado AI Act
US-CO
EU AI Act - High Risk Provisions
EU
GDPR
European Union
Texas AI Act
Texas, USA
Trump Executive Order on AI Policy Framework
US
UK GDPR
United Kingdom

Provision details

Document information
Document
OpenAI Terms of Use
Entity
OpenAI
Document last updated
May 5, 2026
Tracking information
First tracked
March 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-003149
Document ID
CA-D-00009
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
6ae7df627f8ff0f0434212dde1986e4d1bfced272b18d29c3cea01e80cf3dbb0
Analysis generated
March 10, 2026 03:23 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: OpenAI Terms of Use
Record ID: CA-P-003149
Captured: 2026-03-10 03:23:22 UTC
SHA-256: 6ae7df627f8ff0f0…
URL: https://conductatlas.com/platform/openai/openai-terms-of-use/provision/CA-P-003149/model-training-data-use/
Accessed: Aug. 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Model Training Data Use clause do?

This provision establishes differentiated data practices across user tiers, requiring explicit opt-in consent for certain user categories before their content enters model training workflows, while establishing an opt-out mechanism for free users. The clause creates distinct operational pathways for content use depending on account type and user election.

How does this clause affect you?

Free ChatGPT users operate under terms that permit model training use by default, but allow them to disable this through settings modifications. API users and paid non-API users operate under terms that exclude their content from model training unless they affirmatively elect inclusion through opt-in procedures.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 217 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.