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

Corporate Transaction Data Disclosure

Low severity High confidence Explicitdocumentlanguage Rare · 2 of 325 platforms
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Recent governance activity OpenAI recorded 11 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 the operational framework for data portability in M&A and insolvency scenarios, clarifying that personal data constitutes a transferable asset subject to succession rather than requiring individual user authorization for each corporate transaction. It defines the scope of circumstances under which data handling obligations may transfer to a new entity.

Consumer impact (what this means for users)

Under this clause, users' personal data may be transferred to a successor entity upon specified corporate events without requirement for affirmative user consent. The provision extends the applicability of OpenAI's data handling obligations to acquiring or successor entities in defined circumstances.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Business transfers: We may transfer your personal data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of OpenAI's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

— Excerpt from OpenAI's Privacy Policy (ROW)

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-009525
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-009525
Captured: 2026-03-10 03:38:17 UTC
SHA-256: f3c083059dff1a3f…
URL: https://conductatlas.com/platform/openai/privacy-policy-row/corporate-transaction-data-disclosure/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

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Frequently Asked Questions

What does OpenAI's Corporate Transaction Data Disclosure clause do?

This provision establishes the operational framework for data portability in M&A and insolvency scenarios, clarifying that personal data constitutes a transferable asset subject to succession rather than requiring individual user authorization for each corporate transaction. It defines the scope of circumstances under which data handling obligations may transfer to a new entity.

How does this clause affect you?

Under this clause, users' personal data may be transferred to a successor entity upon specified corporate events without requirement for affirmative user consent. The provision extends the applicability of OpenAI's data handling obligations to acquiring or successor entities in defined circumstances.

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.