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OpenAI · openai.com · AI assistants

OpenAI’s legal terms, tracked since February 2026.

OpenAI’s public service terms, privacy policies, data processing addendum and API data controls, with every notable change in plain English.

At a glance
Documents monitored49
Last notable changeSep 30, 2026Service Terms, Connectors and Actions Terms
Notable changes6+ in 8 monthstypical vendor on these pages: 2 in 8 months
Updates detected since February 202690including formatting and page changes
Sub-documents identified so far46linked from OpenAI’s own documents
MonitoringActivesince Feb 15, 2026
Public page updated monthly · Last updated October 8, 2026 · Next update November 1, 2026Legal Sentinel tracks these documents continuously. See it in a demo
What RIAs should know

OpenAI added marketing uses and financial services terms in 2026.

In July 2026, OpenAI’s Privacy Policy added direct marketing as a use of personal data, including on third-party properties, and allowed limited sharing with select marketing partners who are not service providers, subject to user choices.

In September, its Service Terms added a section on ChatGPT for Financial Services: output is informational only, and OpenAI does not provide financial or investment advice through it.

OpenAI’s API data page says data sent to the API is not used to train OpenAI models unless a customer opts in.

What the terms say

What OpenAI’s documents say about client data.

Quoted from the current version of each document. The right-hand column shows how many of the 75 vendors we monitor have a matching clause.

Using customer data to train AI

Addressed

“As of March 1, 2023, data sent to the OpenAI API is not used to train or improve OpenAI models (unless you explicitly opt in to share data with us).”

Platform — Your data · as of Oct 8, 2026 · view source
41%
of monitored vendors (31 of 75)

Sharing data with third parties

Addressed

“When we work with Service Providers, these parties will access, process, or store Personal Data based on our instructions and only in the course of performing their duties to us.”

Privacy Policy · as of Oct 8, 2026 · view source
92%
of monitored vendors (69 of 75)
Change history

What changed, and when.

Notable changes since monitoring began in February 2026, newest first. Each is written from our automated comparison of the before and after versions, then reviewed by a person.

Sep 30, 2026Service TermsAI & data use

Added terms for agentic features, making users responsible for agents’ actions

New Section 14 says users decide how to use agentic features, are responsible for actions agents take for them, and must provide appropriate oversight.

Sep 30, 2026Connectors and Actions TermsLegal terms

Expanded connector access to proactive interactions

Connectors and Actions Terms, updated September 28, 2026, now allow ongoing or proactive interactions, such as subscribing to updates to personalize suggestions.

Sep 23, 2026Platform — Your dataAI & data use

Added Private Safety Processing options for API data retention

Zero Data Retention can now include automated safety monitoring with customer-controlled storage. A Private Retention option keeps content in encrypted abuse-monitoring logs.

Sep 13, 2026Service TermsLegal terms

Added terms for ChatGPT for Financial Services

Output is for informational purposes only. OpenAI does not provide financial or investment advice through these services, and data may be inaccurate, delayed or outdated.

Aug 30, 2026SOC2 reportSecurity

Made its 2026 SOC 2 Type 2 report available

Covers July 1, 2025 to June 30, 2026 and the Security, Availability, Confidentiality and Privacy criteria. Available to authenticated users on the Trust Portal.

Jul 16, 2026Privacy PolicyData sharing

Added direct marketing and sharing with marketing partners to the Privacy Policy

Personal data may be used to promote OpenAI on third-party properties, and limited information shared with select marketing partners who are not service providers.

+ 84 other updates detected, such as formatting, page layout and wording changes.
  • Oct 7, 2026: Terms of Use
  • Oct 4, 2026: OpenAI Academy Terms of Use and Code of Conduct
  • Oct 2, 2026: API Pricing
  • Oct 1, 2026: OpenAI Academy Terms of Use and Code of Conduct
  • Sep 27, 2026: OpenAI Academy Terms of Use and Code of Conduct
  • Sep 24, 2026: OpenAI Academy Terms of Use and Code of Conduct
  • Sep 22, 2026: Security & Privacy
  • Sep 21, 2026: OpenAI Academy Terms of Use and Code of Conduct
Documents monitored

49 OpenAI documents.

Sub-documents are other OpenAI documents that its policies link to, such as addenda and product terms. We list the ones identified so far; there may be others.

DocumentFirst capturedLast changed
Data Processing Addendumopenai.com/policies/data-processing-addendum
Links to 2 sub-documents identified so far
Aug 3, 2026No change detected
OpenAI Data Processing Addendumcdn.openai.com/pdf/openai-data-processing-addendum.pdfAug 3, 2026No change detected
OpenAI Sub-Processor Listplatform.openai.com/subprocessorsAug 21, 2026No change detected
Health Privacy Noticeopenai.com/policies/health-privacy-policy
Links to 1 sub-document identified so far
Aug 3, 2026No change detected
California Privacy Rights Reportingopenai.com/policies/privacy-policy/california-privacy-rights-reportingAug 3, 2026No change detected
Student Data Privacy Agreementcdn.openai.com/osa/openai-sdpa.pdfAug 3, 2026No change detected
Korea Privacy Policy Addendumopenai.com/ko-KR/policies/kr-privacy-policy-addendumAug 6, 2026No change detected
Security & Privacyopenai.com/security-and-privacy
Links to 4 sub-documents identified so far
Mar 9, 2026Sep 22, 2026
Privacy Policy (ROW)openai.com/policies/row-privacy-policyAug 3, 2026Aug 30, 2026
Business data privacyopenai.com/business-data
Links to 2 sub-documents identified so far
Mar 9, 2026Jul 27, 2026
Enterprise privacy at OpenAIopenai.com/enterprise-privacy
Links to 1 sub-document identified so far
Jul 16, 2026Jul 25, 2026
Privacy Policyopenai.com/policies/privacy-policy
Links to 4 sub-documents identified so far
Mar 9, 2026Jul 16, 2026
+ 37 more OpenAI documents monitored.
Questions

OpenAI terms: common questions.

Does OpenAI train its models on API data?

OpenAI’s API data page says that, as of March 1, 2023, data sent to the OpenAI API is not used to train or improve OpenAI models unless the customer explicitly opts in.

Does ChatGPT for Financial Services give investment advice?

OpenAI’s Service Terms, updated in September 2026, say its financial plugins and ChatGPT for Financial Services are for informational purposes only and that OpenAI does not provide financial or investment advice through them.

When did OpenAI last change its terms?

On September 30, 2026, we detected new Service Terms covering agentic features and updated Connectors and Actions Terms. OpenAI’s API data page also changed on September 23, 2026.

Scope and limitations. This page describes what OpenAI’s public documents say as of the dates shown. We monitor the documents listed above; we don’t verify how OpenAI operates in practice, test its security controls or confirm regulatory compliance. It isn’t legal advice, and it doesn’t cover negotiated agreements or order forms. Request a correction · No vendor pays to be listed.