OpenAI · Privacy Policy (ROW) · View original document ↗

Aggregated or De-Identified Data Use

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity OpenAI recorded 16 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)

This provision establishes a data processing pathway that removes personal data from privacy restrictions once de-identification occurs. The authorization to share de-identified data with third parties without limitation creates a category of data outside the scope of personal data restrictions.

Interpretive note: The adequacy of OpenAI's anonymization or de-identification methodology is not described in the policy, and regulatory standards for what constitutes truly anonymous data vary by jurisdiction, creating uncertainty about the scope of this provision's practical effect.

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 11, 2026
Last Seen
This clause type exists across 381 other provisions on other platforms.

Consumer impact (what this means for users)

Users' personal data may be processed into de-identified form and subsequently shared with third parties for any purpose, including commercial or research applications. The terms do not require notice or consent for this de-identification and sharing process once data is rendered non-personally identifiable.

How other platforms handle this

Mixpanel Medium

Mixpanel may use aggregated or de-identified data derived from customer event data for its own purposes, including improving its services, developing new features, and generating analytics insights, provided that such data cannot reasonably be used to identify individual users.

LinkedIn Medium

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined: Data from advertising technologies on and off our Services, like web beacons, pixels, ad ta...

Fiverr Medium

We may de-identify or aggregate your personal information so that it can no longer reasonably identify you, and use such de-identified or aggregated data for any purpose, including sharing with third parties for research, analytics, and marketing purposes, without restriction.

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▸ View Original Clause Language DOCUMENT RECORD
"
We may create aggregated, de-identified, or other anonymous data from your personal data. We make personal data into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for any purpose.

— Excerpt from OpenAI's Privacy Policy (ROW)

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Privacy Policy (ROW)
Entity
OpenAI
Document last updated
March 5, 2026
Tracking information
First tracked
March 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-009526
Document ID
CA-D-00006
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
f3c083059dff1a3f26f2ce10f0072ca60f38c6921517ae6dd07e528e4bfc7ce2
Analysis generated
March 10, 2026 03:38 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenAI
Document: Privacy Policy (ROW)
Record ID: CA-P-009526
Captured: 2026-03-10 03:38:17 UTC
SHA-256: f3c083059dff1a3f…
URL: https://conductatlas.com/platform/openai/privacy-policy-row/aggregated-or-de-identified-data-use/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Aggregated or De-Identified Data Use clause do?

This provision establishes a data processing pathway that removes personal data from privacy restrictions once de-identification occurs. The authorization to share de-identified data with third parties without limitation creates a category of data outside the scope of personal data restrictions.

How does this clause affect you?

Users' personal data may be processed into de-identified form and subsequently shared with third parties for any purpose, including commercial or research applications. The terms do not require notice or consent for this de-identification and sharing process once data is rendered non-personally identifiable.

Is ConductAtlas affiliated with OpenAI?

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