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

Use of Aggregated or De-identified Data

Low severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

OpenAI states it may use and share data that has been stripped of direct identifiers or combined across users for any purpose, including with third parties, without restriction.

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 policy authorizes unrestricted use and sharing of aggregated or de-identified data; the practical privacy implications depend on the robustness of the de-identification process, which the policy does not detail.

Interpretive note: The practical privacy implications of this provision depend on the technical robustness of OpenAI's de-identification process, which is not described in the policy.

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)

Once data is classified as aggregated or de-identified under OpenAI's standards, the policy states it may be used and shared for any purpose with third parties. The standards and technical processes used to achieve de-identification are not described in the 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 use Aggregated or De-Identified Data for any purpose and share it with third parties. "De-Identified Data" means data that is reasonably unlikely to identify you, and "Aggregated Data" means data that has been combined with data from many users such that it no longer reflects or references an individual.

— Excerpt from OpenAI's Privacy Policy (ROW)

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: CCPA and CPRA include definitions of de-identified data and impose obligations on businesses to commit to not re-identifying such data; the policy's definition of 'reasonably unlikely to identify you' aligns broadly with a risk-based standard but may require evaluation against CPRA's specific requirements. GDPR does not recognize de-identified data as falling outside its scope unless anonymization meets a high technical standard; pseudonymized data remains within GDPR scope. The FTC has noted concerns about re-identification risks in published guidance. GOVERNANCE EXPOSURE: Low to Medium. The policy's broad permission to use de-identified data for any purpose is standard in industry practice but creates residual risk if de-identification is insufficiently robust. The lack of technical specificity about de-identification methods makes independent verification difficult. JURISDICTION FLAGS: California CPRA requires specific organizational and technical measures supporting de-identification claims. GDPR's anonymization standard is high; data that is merely pseudonymized remains regulated. Organizations processing sensitive data through OpenAI should assess whether de-identification of derived outputs meets applicable standards. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should assess whether outputs generated from their data, once de-identified, could inform competitor-accessible models or shared analytics. DPAs should address how de-identified data derived from enterprise inputs is treated. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether OpenAI's de-identification standard satisfies applicable jurisdiction-specific definitions and whether contractual commitments against re-identification are sufficient for their deployment context.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has issued guidance on de-identification practices and re-identification risks as part of its consumer privacy enforcement mandate.
    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-011114
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-011114
Captured: 2026-03-10 03:38:17 UTC
SHA-256: f3c083059dff1a3f…
URL: https://conductatlas.com/platform/openai/privacy-policy-row/use-of-aggregated-or-de-identified-data/
Accessed: July 4, 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 Use of Aggregated or De-identified Data clause do?

The policy authorizes unrestricted use and sharing of aggregated or de-identified data; the practical privacy implications depend on the robustness of the de-identification process, which the policy does not detail.

How does this clause affect you?

Once data is classified as aggregated or de-identified under OpenAI's standards, the policy states it may be used and shared for any purpose with third parties. The standards and technical processes used to achieve de-identification are not described in the policy.

Is ConductAtlas affiliated with OpenAI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenAI.