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
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
Zoom may obtain and aggregate technical and other data about your and your End Users use of the Services and Software on a de-identified or anonymized basis...and Zoom may use the Aggregated Anonymous Data in accordance with applicable Law...
Cloudflare...shall have the right to use Network Data for purposes of providing, maintaining, developing, and improving its Services.
We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service...
"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 usedExcerpt from OpenAI's Privacy Policy (ROW)
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.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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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.
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.
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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