OpenAI · OpenAI Terms of Use · View original document ↗

User Content License for Model Training

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

When you use ChatGPT or other OpenAI services, you give OpenAI permission to use what you type to improve its AI, unless you turn off this option in your account settings.

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)

The terms authorize OpenAI to use input content for model training by default, which means conversation data including any personal or sensitive information in prompts may be used for AI development unless users actively opt out.

Interpretive note: The exact license language could not be directly extracted from the corrupted PDF; the provision description reflects the known structure of OpenAI's publicly referenced Terms of Use as identified through the document metadata and annotation links.

Consumer impact (what this means for users)

This provision authorizes OpenAI to use the content users submit, including prompts and conversation data, to train and improve its AI models by default; users must affirmatively opt out through account settings to prevent this use.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Log in to your ChatGPT account, navigate to Settings, then Data Controls, and disable the option for 'Improve the model for everyone' to opt out of having your conversations used for model training.

How other platforms handle this

Ideogram Medium

We may use the content you provide to us, including prompts and generated images, to train and improve our AI models and services.

Windsurf Medium

We may leverage OpenAI models independent of user selection for processing other tasks (e.g. for summarization). We may leverage Anthropic models independent of user selection for processing other tasks (e.g. for summarization). We may leverage these models independent of user selection for processi...

Supabase Medium

After registration, you may create, upload or transmit files, documents, videos, images, data or information as part of your use of the Service (collectively, "User Content"). This includes any inputs you provide to our AI-powered support tools and outputs generated in response to your inputs. User ...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
By using our Services, you grant OpenAI a worldwide, non-exclusive, royalty-free license to use, reproduce, modify, distribute, and create derivative works from your content for the purpose of operating, improving, and developing our Services and models. You may opt out of having your content used to train our models by adjusting your account settings.

— Excerpt from OpenAI's OpenAI Terms of Use

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1. REGULATORY LANDSCAPE: This provision engages GDPR Article 6 lawful basis requirements and Article 22 on automated decision-making for EU users (though EU users are subject to separate terms); CCPA Section 1798.100 et seq. regarding consumers' rights to opt out of certain uses of personal information; and FTC guidelines on data use disclosures. For EU users, GDPR requires a clear lawful basis for processing personal data for AI training purposes, and a broad default opt-in structure may conflict with consent or legitimate interests requirements depending on the data involved. 2. GOVERNANCE EXPOSURE: High. Default opt-in to model training using user-submitted content creates material compliance exposure for organizations deploying OpenAI to employees or customers, particularly where prompts may contain personal data, proprietary information, or sensitive categories of data. The opt-out mechanism mitigates but does not eliminate this exposure. 3. JURISDICTION FLAGS: California residents may have CCPA rights to know about and limit certain uses of personal information. EU and UK users are directed to the EU Terms of Use, which may provide different or stronger protections. Healthcare organizations should assess whether HIPAA-regulated information could enter prompts and whether the training data use provision is compatible with HIPAA requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise and API customers should confirm whether the Business Terms or Data Processing Agreement (DPA) at openai.com/policies/service-terms/ provides stronger data use limitations, as the consumer Terms of Use default may not be appropriate for business deployments involving customer or employee data. Vendor risk assessments should document the opt-out status and confirm it is applied at the organizational level. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether the training data opt-out has been enabled for all organizational accounts, update data processing records to reflect OpenAI as a processor or controller (depending on the applicable agreement), and assess whether privacy notices to end users adequately disclose this data use. Organizations in regulated sectors should evaluate whether submitting regulated data to OpenAI services is permissible under their applicable frameworks.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over consumer data use disclosures and practices under the FTC Act, including default opt-in data collection practices in consumer-facing AI services
    File a complaint →
  • State AG
    California Attorney General has enforcement authority under CCPA regarding consumer rights to limit use of personal information for AI model training
    File a complaint →

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-011781
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-011781
Captured: 2026-03-10 03:23:22 UTC
SHA-256: 6ae7df627f8ff0f0…
URL: https://conductatlas.com/platform/openai/openai-terms-of-use/user-content-license-for-model-training/
Accessed: May 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 User Content License for Model Training clause do?

The terms authorize OpenAI to use input content for model training by default, which means conversation data including any personal or sensitive information in prompts may be used for AI development unless users actively opt out.

How does this clause affect you?

This provision authorizes OpenAI to use the content users submit, including prompts and conversation data, to train and improve its AI models by default; users must affirmatively opt out through account settings to prevent this use.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.