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When Perplexity changes or adds an AI model provider, it provides notification but does not offer a pre-appointment objection period; Customer's only available recourse upon objection is to cease use of the relevant model.
This analysis describes what Perplexity AI'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
This provision establishes a differentiated notification regime for AI Model Providers compared to general subcontractors, removing the pre-appointment objection window and limiting Customer's remedies to cessation of use of the affected model rather than termination of the Agreement.
Interpretive note: Whether the notification-only approach for Model Providers satisfies GDPR Article 28(2) sub-processor authorization requirements is subject to regulatory interpretation and may vary by supervisory authority guidance.
This high-severity addition creates a specific notification regime for AI model providers, representing heightened scrutiny over which third-party LLMs process customer data due to the sensitivity of generative AI dependencies.
View full change record →Under this clause, when Perplexity changes an AI model provider, the agreement does not provide a pre-appointment objection right or a termination remedy; the agreement requires that Customers who object cease use of the relevant model.
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"If Perplexity appoints a new subcontractor or intends to make any changes concerning the addition or replacement of any subcontractor that provides large language models or other generative artificial intelligence models (a "Model Provider"), Perplexity will notify Customer (email sufficient) and will update the list of "Third-Party Providers" set forth at www.perplexity.ai/hub/legal/third-party-models (each of which is, for clarity, a Model Provider under this DPA). If Customer objects to the appointment or replacement, Customer's sole recourse is to (and Customer must) cease all use of the relevant Third-Party Model via the Services (which, for clarity, Customer may do at any time after the appointment or replacement).Excerpt from Perplexity AI's Perplexity Data Processing Addendum
REGULATORY LANDSCAPE: This provision engages GDPR Article 28(2), which requires that processors obtain prior authorization from controllers before engaging new sub-processors, and comparable requirements under UK GDPR. The DPA's notification-only approach for Model Providers, without a pre-appointment objection right, may require evaluation under GDPR Article 28(2) requirements and guidance from the Irish DPC and other EU supervisory authorities. US state privacy laws with processor or service provider requirements may also be implicated. GOVERNANCE EXPOSURE: High. The removal of a pre-appointment objection right for Model Providers is operationally significant for data protection programs that require controller approval of sub-processor changes. GDPR Article 28(2) establishes that processors must give controllers the opportunity to object before a new sub-processor begins processing; the DPA's post-appointment-only notification for Model Providers may require evaluation against this standard. JURISDICTION FLAGS: EU/EEA and UK data subjects create the highest exposure given GDPR and UK GDPR sub-processor authorization requirements. California CCPA service provider chain-of-custody requirements and equivalent US state laws may also be relevant. Legal teams in regulated industries (financial services, healthcare) should assess whether this mechanism satisfies sector-specific vendor management requirements. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should note that this provision limits remedies to cessation of model use, without refund or termination rights, in contrast to the general subcontractor regime which provides a termination and refund remedy. This asymmetry may require additional contractual protections for customers with strict sub-processor approval requirements. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should monitor the Third-Party Providers list at www.perplexity.ai/hub/legal/third-party-models for changes, assess whether the notification-only regime satisfies their GDPR Article 28 obligations, and consider whether supplemental contractual amendments are required to secure pre-appointment approval rights for Model Provider changes.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes a differentiated notification regime for AI Model Providers compared to general subcontractors, removing the pre-appointment objection window and limiting Customer's remedies to cessation of use of the affected model rather than termination of the Agreement.
Under this clause, when Perplexity changes an AI model provider, the agreement does not provide a pre-appointment objection right or a termination remedy; the agreement requires that Customers who object cease use of the relevant model.
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