8 Total
1 High severity
6 Medium severity
1 Low severity
Summary

This document establishes Replicate's data collection and processing practices for users of its AI model platform. The policy authorizes the collection of account information, payment data, and training data uploaded by users to build AI models, and permits disclosure of such data to third-party service providers including payment processors, analytics vendors, and parties involved in potential business transactions. Users may request access to, correction of, or deletion of their personal information by contacting privacy@replicate.com.

Technical / Legal Breakdown

This document is Replicate LLC's privacy policy (last updated April 1, 2026) governing the collection, use, sharing, and retention of personal information across its website and AI model deployment services. The policy states that Replicate collects account registration data, billing and payment information, training data uploaded by users (which may include sensitive information under various privacy laws), website analytics and metadata, and third-party sourced professional enrichment data; the terms authorize sharing this information with corporate affiliates, vendors, payment processors, and prospective acquirers in business transitions. Notably, the policy states that Replicate does not 'sell' or 'share' personal information as defined by U.S. state privacy laws and designates itself as a 'processor' or 'service provider' in relation to customer personal information, though the breadth of the training data collection provision and the policy change mechanism (revision without prior notice, update reflected only by effective date) warrant scrutiny. The policy engages CCPA and analogous U.S. state privacy frameworks, COPPA (minors under 16), and potentially GDPR where EU-based users interact with the platform, though the document does not address GDPR-specific mechanisms such as lawful basis, data transfer safeguards, or a designated EU representative. Compliance teams should note the absence of explicit data retention schedules, the self-designation as processor or service provider without elaboration on sub-processor obligations, and the lack of a structured policy change notification mechanism.

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High — 1 provision
Medium — 6 provisions
Low — 1 provision

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Mapped Governance Frameworks

CCPA/CPRA
California, USA
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Connecticut Data Privacy Act Amendments
US-CT
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FTC Act Section 5
United States Federal
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GDPR
European Union
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Indiana Consumer Data Protection Act
US-IN
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Kentucky Consumer Data Protection Act
US-KY
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Universal Opt-Out Mechanism Expansion 2026
US
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Archival ProvenanceSource & Archival Record
Last Captured April 29, 2026 08:16 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000466
Version ID CA-V-001039
SHA-256 1707766d45e2786929826c5f6bb1f454c3d2496d6c614babeab5c35585493295
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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