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
The updated policy establishes a new Files API feature allowing you to upload and store files for use with inference requests. Files are encrypted at rest and in transit, retained until you delete them or close your account, and transmitted to the model provider you select for processing. OpenRouter states it does not use uploaded file content to train its own models, for unrelated analytics, or for marketing. The policy also raises the minimum age requirement from 13 to 18 years old, meaning users under 18 are no longer eligible to use the service.
View change record →The updated policy discloses that when you submit text, audio, video, or image data to OpenRouter's service, that data is transmitted to third-party AI model providers, which may use your inputs for model training and improvement unless you select a model provider that commits to not using data for training. The policy now explicitly describes biometric processing features (voice cloning, face cloning, speaker identification) that certain models perform, and states that you are responsible for obtaining consent from any identifiable individuals whose voice or image you submit to these features. You can review model provider data practices linked in the policy and select a model or provider that does not use data for training if you prefer not to have your inputs used for model improvement.
View change record →How other platforms handle this
We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts
Patreon transfers of personal data of individuals in the European Union (including EFTA States) and the UK outside of those locations are performed based on contractual obligations placed on the recipient of the personal data.
As required by applicable law, we collect and process information about individuals in the EEA, Switzerland, and UK only where we have a legal basis for doing so.
"When information is transferred outside the EEA or UK, we ensure it benefits from an adequate legal protection by relying on (1) adequacy decisions from the European Commission...and (2) standard contractual clauses approved by the European Commission under Article 46 of the GDPR...Excerpt from OpenRouter's Privacy Policy
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The clause states: “When information is transferred outside the EEA or UK, we ensure it benefits from an adequate legal protection by relying on (1) adequacy decisions from the European Commission...and (2) standard contractual clauses approved by the European Commission under Article 46 of the GDPR...”
ConductAtlas has identified this type of provision across 264 platforms. See the full comparison.
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