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

De-identification and Aggregate Data Use

Low severity Explicit document language Common · 279 of 352 platforms
Stay ahead of the changes
Track OpenAI and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

The policy states that personal data may be aggregated or de-identified and used for analytics, service improvement, and research, and that OpenAI commits to maintaining de-identified data in that form without attempting re-identification except as legally required.

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

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 3333 other provisions on other platforms.

Consumer impact (what this means for users)

Under this clause, personal data that has been de-identified prior to a user's deletion request may not be subject to deletion, as the policy states in the retention section that data already de-identified and disassociated from an account when used for model improvement may persist after account deletion.

How other platforms handle this

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

ZipRecruiter Medium

We will only use your Personal Data to provide services directly to you...and/or to provide services to you on behalf of our clients...except as otherwise described in this Privacy Policy or with your consent.

Glassdoor Medium

We may use your personal data to conduct research...we conduct and publish research about the labor market, the economy, job opportunities, jobseeker and employee behaviors...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We also aggregate or de-identify Personal Data so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Services are being used

Excerpt from OpenAI's Privacy Policy (ROW)

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR recitals and guidance regarding anonymization and pseudonymization, where truly anonymized data falls outside GDPR scope while pseudonymized data does not.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

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
July 9, 2026
Record ID
CA-P-013580
Document ID
CA-D-00006
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0d4e62bf4eda61a32184e00eb5fb60bdf91b933dbfa28a82e1a6dab349128337
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-013580
Captured: 2026-03-10 03:38:17 UTC
SHA-256: 0d4e62bf4eda61a3…
URL: https://conductatlas.com/platform/openai/privacy-policy-row/provision/CA-P-013580/de-identification-and-aggregate-data-use/
Accessed: Aug. 2, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

Related Analysis

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does OpenAI's De-identification and Aggregate Data Use clause do?

The policy states that personal data may be aggregated or de-identified and used for analytics, service improvement, and research, and that OpenAI commits to maintaining de-identified data in that form without attempting re-identification except as legally required.

How does this clause affect you?

Under this clause, personal data that has been de-identified prior to a user's deletion request may not be subject to deletion, as the policy states in the retention section that data already de-identified and disassociated from an account when used for model improvement may persist after account deletion.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 279 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.