A Big One

OpenAI has reversed its categorical denial of cross-context behavioral advertising and now affirmatively does it. The previous policy stated plainly that OpenAI does not "sell" or "share" personal data for cross-contextual behavioral advertising and does not process personal data for targeted advertising purposes. That sentence is gone.

In its place: a new "Your Opt-Out Rights" subsection that acknowledges OpenAI may now share data with marketing partners on third-party properties, language explicitly identifies as "targeted advertising" or sharing for "cross-context behavioral advertising" under certain state privacy laws, with an account-settings opt-out.

A new outbound data-use purpose has been added — promoting OpenAI products on third-party properties and measuring the effectiveness of those efforts — and the existing "Vendors and Service Providers" category has been expanded to "Vendors, Service Providers, and Marketing Partners," with explicit disclosure that some of these partners may receive information through cookies and similar technologies. Marketing partners are categorically different from service providers under state privacy law: they're independent recipients, not contractors acting on OpenAI's instructions.

Two further details: the bulleted list of four enumerated user rights (access, deletion, correction, freedom from retaliation) has been deleted entirely. And the URL path has shifted from /policies/row-privacy-policy/ to /policies/us-privacy-policy/, formalizing a EU/non-EU geo-split flagged in a prior diff.

Why this matters: We previously caught the inbound leg — OpenAI receiving advertiser data. This week documents the outbound leg. The infrastructure is now bidirectional and operational. Free and Go tier creators using ChatGPT are now part of a cross-context behavioral advertising program by OpenAI's own admission, with opt-out as the only protection.

In human terms: A freelance motion designer uses ChatGPT Free to brainstorm storyboard concepts for a sneaker brand. Over the next few days, the editing-software and camera-gear ads they see on news sites and YouTube are unusually well-targeted to that exact project — because OpenAI now shares engagement signals with marketing partners on third-party properties. The opt-out exists in their account settings, but they didn't know to look for it.