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

Business Transaction Data Transfer

Low severity High confidence Explicitdocumentlanguage Rare · 2 of 343 platforms
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Document Record

What it is

If OpenAI is sold, merges with another company, or goes through bankruptcy, your personal data may be transferred to the new owner as a business asset.

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 authorizes transfer of user personal data, including conversation content, to unknown third-party entities in the event of a corporate transaction, potentially under different privacy terms.

Clause Stability Stable

0
Changes
3
Months Monitored
May 12, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Consumer impact (what this means for users)

The policy states that personal data may be transferred to acquirers or successors in a merger, sale, or insolvency event. The privacy practices of the successor entity are not governed by this policy.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may disclose Personal Data to acquirers, successors, or assignees as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Data is transferred to one or more third parties as one of our business assets.

— Excerpt from OpenAI's Privacy Policy (ROW)

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: GDPR requires that data transfers in M&A contexts maintain lawful basis and that data subjects may need to be notified; this provision would be subject to the separate EEA policy for those users. U.S. state privacy laws including CCPA generally require updated privacy notices when material changes to data practices occur following a transaction. The FTC has historically scrutinized asset sales involving consumer data. GOVERNANCE EXPOSURE: Low to Medium. Business transaction transfer clauses are standard in privacy policies. The practical exposure arises if the acquiring entity materially changes data practices, in which case notice and potentially consent obligations may arise under applicable law. JURISDICTION FLAGS: EEA users retain GDPR protections regardless of corporate transaction; a transfer to a new controller would require a lawful basis and potentially new transparency notices. California CPRA requires businesses to honor privacy rights even through business transitions. CONTRACT AND VENDOR IMPLICATIONS: Organizations with contractual data protection obligations to their own customers should consider whether an OpenAI acquisition scenario could affect their compliance posture and whether their contracts with OpenAI include change-of-control provisions. COMPLIANCE CONSIDERATIONS: Legal teams should monitor for any announcements of corporate transactions involving OpenAI and assess whether updated data processing agreements or user notices are required as a result.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC oversees M&A transactions involving consumer data and has taken action to protect consumer privacy in asset sales.
    File a complaint →

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
EU AI Act - High Risk Provisions
EU
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
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-011112
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-011112
Captured: 2026-03-10 03:38:17 UTC
SHA-256: f3c083059dff1a3f…
URL: https://conductatlas.com/platform/openai/privacy-policy-row/business-transaction-data-transfer/
Accessed: June 28, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenAI's Business Transaction Data Transfer clause do?

This provision authorizes transfer of user personal data, including conversation content, to unknown third-party entities in the event of a corporate transaction, potentially under different privacy terms.

How does this clause affect you?

The policy states that personal data may be transferred to acquirers or successors in a merger, sale, or insolvency event. The privacy practices of the successor entity are not governed by this policy.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 2 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.