OpenRouter · OpenRouter Privacy Policy · View original document ↗

Automatic Collection of Behavioral and Device Data

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

What it is

The policy states that OpenRouter automatically collects traffic data, location data, log files, browser history, search queries, clicked links, page views, IP address, operating system, browser type, time zone, and other unique device or online identifiers as users interact with the Site or Service.

This analysis describes what OpenRouter'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 authorizes collection of a broad set of behavioral and device-level identifiers through automatic technologies, including data categories such as location data and browser history that may constitute personal data or sensitive data under applicable privacy frameworks.

Change history

added May 24, 2026

This provision explicitly details automatic data collection of behavioral and device information, significantly expanding transparency about what data is automatically captured beyond just cookies.

View full change record →

Consumer impact (what this means for users)

The agreement establishes that device identifiers, location data, browsing history, and IP addresses are collected automatically without requiring affirmative user action, and these data types may be used in conjunction with cookies to build behavioral profiles or deliver personalized content.

How other platforms handle this

eBay Medium

We collect your personal data when you use our Services, create a new eBay account, provide us with information via a web form, add or update information in your eBay account, participate in online community discussions or otherwise interact with us.

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.

Strava Medium

If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
As you navigate through and interact with our Site or Service, we may use automatic data collection technologies to collect certain information about your device, browsing actions and patterns, including: Details of your visits to our Site, including, but not limited to, traffic data, location data, log files to understand how our Service is performing, browser history, search, information about links you click, pages you view, and other communication data and the resources that you access and use on the Site. Information about your computer and internet connection, including your IP address, operating system and browser type, time zone setting, and other unique personal or online identifiers.

— Excerpt from OpenRouter's OpenRouter Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Automatic collection of IP addresses, location data, and device identifiers constitutes personal data processing under GDPR, requiring a lawful basis for each processing purpose. The CCPA classifies IP addresses, browsing history, and geolocation as personal information categories subject to disclosure and opt-out obligations. The FTC Act's framework for unfair or deceptive data practices applies to the adequacy of disclosures about automatic collection. GOVERNANCE EXPOSURE: Medium. The policy's enumeration of collected data categories is reasonably specific, but the phrase 'including but not limited to' preserves flexibility for additional undisclosed collection. Location data collection in particular may require heightened disclosure or consent under various state privacy laws. JURISDICTION FLAGS: EU and EEA users have heightened exposure given that behavioral tracking and device identifier collection requires a lawful GDPR basis, which the policy does not specify by processing category. California users have CCPA rights over geolocation, browsing history, and IP address data. Illinois users should note that unique biometric or device identifiers may implicate BIPA depending on the specific technologies deployed. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers whose employees use OpenRouter should assess whether automatic collection of device identifiers and behavioral data from corporate devices creates obligations under their own privacy programs or employment agreements. COMPLIANCE CONSIDERATIONS: Compliance teams should request a data inventory from OpenRouter specifying the precise automatic collection technologies in use, retention periods for each data category, and the third parties with whom automatically collected data is shared. The adequacy of cookie consent mechanisms under GDPR's ePrivacy requirements should also be evaluated.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive data collection practices, including the adequacy of disclosures about automatic device and behavioral data collection
    File a complaint →

Applicable regulations

Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
OpenRouter Privacy Policy
Entity
OpenRouter
Document last updated
May 12, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-012761
Document ID
CA-D-00811
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
dfc26af0d938f539393c1d50bf9e961784acc942ecc6dcc4ea7ec472eb216042
Analysis generated
May 21, 2026 01:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenRouter
Document: OpenRouter Privacy Policy
Record ID: CA-P-012761
Captured: 2026-05-21 01:12:10 UTC
SHA-256: dfc26af0d938f539…
URL: https://conductatlas.com/platform/openrouter/openrouter-privacy-policy/automatic-collection-of-behavioral-and-device-data/
Accessed: June 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does OpenRouter's Automatic Collection of Behavioral and Device Data clause do?

This provision authorizes collection of a broad set of behavioral and device-level identifiers through automatic technologies, including data categories such as location data and browser history that may constitute personal data or sensitive data under applicable privacy frameworks.

How does this clause affect you?

The agreement establishes that device identifiers, location data, browsing history, and IP addresses are collected automatically without requiring affirmative user action, and these data types may be used in conjunction with cookies to build behavioral profiles or deliver personalized content.

Is ConductAtlas affiliated with OpenRouter?

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