Poliogo

What OpenAI means for your privacy policy

Sending a user's text to a model is a disclosure obligation in its own right: the EU AI Act asks you to say an AI system is in use, and GDPR Article 22 asks whether a decision was made about somebody by a machine. Poliogo finds OpenAI in your code, writes the clauses it forces into your documents, and shows you the diff before anything is published.

Detected automaticallyMoves your Privacy PolicyUnited States
OpenAI detected
What changed in your product
Your Privacy Policy does not mention OpenAI.
↓
What we updated for you
Privacy Policy updated, with OpenAI named and its purpose stated.
Proved from your own code, with the file and line beside it.
21
stacks with a page of their own
50+
services the scan classifies
<5 min
signup to finished documents

Compliance on a OpenAI project, end to end

The clauses are the visible part. What makes them worth having is that they keep matching the code after you stop paying attention.

It finds it without being told

Automatic

OpenAI resolves from its package, its endpoint or its credential name — so an integration with no SDK installed is found like any other.

Clauses, not a template

The disclosures OpenAI forces are assembled from a library built from published regulatory text, and filled in from the catalog row rather than from a guess about what the vendor does.

Every clause explained

Beside each one, in plain English: what it means, why your product needs it, and which detected component put it there — with the file and line it was proved from.

It notices when this changes

Drift

Later scans are diffed against the snapshot your documents were generated from, so removing OpenAI or adding something beside it becomes an update you approve.

Delivered where you work

As a pull request on a connected Git host, as an approval in the dashboard, or from your editor over MCP — the same six tools your agent can call without opening a browser.

Read in memory, not retained

The files a scan reads are processed in memory and dropped when the request ends; what is kept is the list of services it found. The MCP server goes further and scans on your own machine.

How Poliogo proves OpenAI is there

Detection is pattern matching over what is literally in your repository — dependency manifests, source files, configuration, edge functions and `.env.example` — not a model's opinion about your code. OpenAI resolves from any of the signatures below, so an integration written as a bare `fetch` with no package installed is found exactly like one with an SDK.

  • ✓Detected from the endpoint api.openai.com as well as from the openai package and a gpt-4 model identifier in config, so an integration with no dependency installed is still found and still disclosed.
  • ✓The generated disclosure states OpenAI's actual default rather than the cautious version: API data is not used to train its models, and inputs and outputs are held up to 30 days for abuse monitoring, then deleted.
  • ✓Prompts and completions are user content, so an erasure request has to reach them — the retention clause names the 30-day window instead of leaving a reader to assume it is forever.

What OpenAI changes in your documents

OpenAI processes your users' prompts — this adds AI transparency and retention notices. User data sent to an AI provider needs training, retention and automated-decision disclosures. That is why OpenAI moves your Privacy Policy — and it is the same sentence the Updates page shows when a scan finds it for the first time, because both are read from one place.

OpenAI — generated clauses
Data
OpenAI receives: prompts, uploaded files, conversation history, generated output
Why
Purpose: generating text, embeddings and other ai output
Transfer
Processed in: United States
Entity
Sub-processor of record: OpenAI, L.L.C.
  • ✓Privacy Policy — regenerated and shown as a diff before anything is published.

Training and retention: what OpenAI publishes

The EU AI Act asks you to say that an AI system is in use, and GDPR Article 22 asks whether a decision about somebody was made by a machine. Neither question is answered by naming the vendor, so the generated disclosure states the provider's published position rather than a reassuring paraphrase of it.

  • ✓Training — OpenAI does not use data submitted through its API to train its models by default.
  • ✓Retention — API inputs and outputs are retained by OpenAI for up to 30 days for abuse monitoring, then deleted.
  • ✓Both sentences are drawn from the provider's own published terms, and both are shown to you before a word is published.

OpenAI in your sub-processor schedule

A sub-processor schedule names the legal entity, not the brand — OpenAI, L.L.C. rather than "OpenAI" — because that is the name a customer's data protection agreement is checked against. The row below is what Poliogo generates and what your Trust Center publishes.

FieldValue
Legal entityOpenAI, L.L.C.
What it receivesPrompts, uploaded files, conversation history, generated output
PurposeGenerating text, embeddings and other AI output
Processing locationUnited States
Their privacy policyopenai.com/policies/privacy-policy

Generated from the catalog entry, and published on your Trust Center alongside every other sub-processor a scan found.

Getting this onto a OpenAI project

Nothing is written or published until you have seen it. The scan proposes, you approve, and only then does anything reach your repository or your live pages.

1
Connect

Connect the repository, the host or the live address. The scan reads manifests, source, configuration and `.env.example` in memory and keeps the list of services it found, not the files it read.

2
Check what it found

A plain-English list of every service the scan proved, OpenAI among them, each with the file and the line it was found on. Correct anything wrong before a word is generated.

3
Generate and review

Privacy Policy, Cookie Policy and Terms, with the clauses OpenAI forces already in them, and a plain-language explanation beside each one saying which detected component put it there.

4
Keep them current

Later scans are diffed against the snapshot your documents were generated from, so a service added next month becomes an update you approve rather than a quiet inaccuracy nobody notices.

Questions people ask

Does Poliogo detect OpenAI on its own?

Yes. OpenAI resolves from the signatures in the detection library — the package name, the endpoint it is called at, and the credential name it uses in `.env.example`. Matching on the endpoint is the part that matters: an integration written as a bare `fetch` with nothing added to package.json is still found, and that is the case a dependency-only scanner misses entirely.

What does OpenAI actually receive from my users?

Prompts, uploaded files, conversation history, generated output — for generating text, embeddings and other ai output. That list is not written for this page: it is the catalog row the generated Privacy Policy prints, so what you read here is what your document will say, down to the categories.

Do I have to list OpenAI as a sub-processor?

If it processes personal data on your behalf, yes — and the row names OpenAI, L.L.C., the legal entity, rather than the brand, because that is the name a customer's data protection agreement is checked against. Poliogo generates the row and publishes it on your Trust Center alongside every other sub-processor a scan found.

Where does OpenAI process the data?

United States. That matters for the transfer clause rather than for the vendor list: an EU product sending personal data to a US processor owes a transfer disclosure whether or not anything else in the stack is American. The generated clause names the location from this same row rather than assuming one.

Does OpenAI need anything in my cookie banner?

Not on its own — the catalog carries no cookies for OpenAI, so it appears in your Privacy Policy and your sub-processor schedule rather than in the cookie table. Services are classified one at a time from what they actually set, which is why a product can owe a long sub-processor list and still have a short banner.

What happens when I add another service later?

A scan has to run first — manually on any plan including Free, or on your plan's schedule from Starter. When one finds a service your documents do not mention, the change arrives as a proposal with a plain-language diff: what changed, why, and which detected component triggered it. On a connected Git host it can also arrive as a pull request on a side branch, so changes reach your default branch only through a pull request you approve.

Is any of this legal advice?

No. Poliogo reads code and assembles clauses from a library built from published regulatory text; it does not weigh your circumstances, and no generated document settles whether a business is compliant — that turns on how the business actually handles data. What the product is for is making sure the documents describe what the software genuinely does, which is the part that goes stale on its own and the part a person cannot check by hand every week.

See what a scan finds in your OpenAI project

Connect it and read the list before anything is generated. Free plan, no credit card, nothing published until you approve it. Poliogo automates the reading and the drafting, not the judgement — it is not a law firm and this page is not legal advice.

Start free — no credit card

Poliogo is an automated code analysis and document display tool, not a law firm. Poliogo does not provide legal advice, representation, or guarantees of statutory compliance, ADA/WCAG certification, or legal immunity. Visual banners and generated documents are advisory tools and do not substitute for professional legal review.