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

Cross-Border Data Transfers to the United States

High severity Rare · 1 of 343 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)

The provision establishes the operational basis for cross-border data flows and clarifies that OpenAI's data processing infrastructure is not geographically limited to the user's jurisdiction. This informs users of the extraterritorial scope of data handling practices under the terms.

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 9, 2026
First Seen
Apr 10, 2026
Last Seen
This clause type exists across 1153 other provisions on other platforms.

Consumer impact (what this means for users)

Users acknowledge through continued service use that their Personal Data will be subject to transfer and processing across multiple jurisdictions, including the United States, under varying data protection regimes. The terms establish that users accept this cross-border data flow mechanism as a condition of service access.

How other platforms handle this

Fiverr Medium

Your personal information may be transferred to and processed in countries outside your country of residence, including the United States and Israel, which may have data protection laws that differ from those in your country. We rely on appropriate safeguards, such as standard contractual clauses ap...

DocuSign Medium

When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to other countries that have not been found to provide an adequate level of data protection, we use legal mechanisms such as Standard Contractual Clauses approved by the European Commission to h...

Peloton Medium

Your personal information may be transferred to, processed and stored in countries other than the country in which you are resident, including the United States, Australia, Canada, the European Union and the UK. We take appropriate safeguards to protect your personal information in accordance with t...

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▸ View Original Clause Language DOCUMENT RECORD
"
OpenAI is based in the United States. When you use our services, your Personal Data may be transferred to, stored, and processed in the United States or other countries where we or our service providers operate. By using our services, you acknowledge that your Personal Data may be transferred to countries that may not have the same data protection laws as your country of residence.

— Excerpt from OpenAI's Privacy Policy (ROW)

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
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-002440
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-002440
Captured: 2026-03-10 03:38:17 UTC
SHA-256: f3c083059dff1a3f…
URL: https://conductatlas.com/platform/openai/privacy-policy-row/cross-border-data-transfers-to-the-united-states/
Accessed: June 18, 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 Cross-Border Data Transfers to the United States clause do?

The provision establishes the operational basis for cross-border data flows and clarifies that OpenAI's data processing infrastructure is not geographically limited to the user's jurisdiction. This informs users of the extraterritorial scope of data handling practices under the terms.

How does this clause affect you?

Users acknowledge through continued service use that their Personal Data will be subject to transfer and processing across multiple jurisdictions, including the United States, under varying data protection regimes. The terms establish that users accept this cross-border data flow mechanism as a condition of service access.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 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.