Litmus

Contract Diff Analysis

Key Limitation

The supplied diff does not include the actual contractual language. It only states:

> “Added approximately 2807 words to the document”

Without the added, deleted, or replaced text, it is not possible to reliably identify:

• Changes to customer data rights or permitted uses
• Whether customer data may be used to train, fine-tune, or evaluate AI models
• New data-sharing or disclosure rights
• Changes to confidentiality, security, retention, or deletion obligations
• Changes to intellectual-property ownership
• New warranties, indemnities, liability limitations, or compliance obligations
• Whether the customer has an opt-out or consent right regarding AI training

AI-Training Review

No conclusion can be drawn about AI-model training from the information provided. The added language should be reviewed specifically for terms such as:

• “train,” “fine-tune,” “improve,” or “develop” models or services
• “machine learning,” “artificial intelligence,” or “generative AI”
• Use of “customer data,” “content,” “inputs,” “outputs,” or “usage data”
• Rights to create “aggregated,” “de-identified,” or “derived” data
• Use of data by affiliates, subprocessors, or third-party model providers
• Retention of data after termination
• Customer consent, notice, or opt-out mechanisms
• Restrictions on using data to train models available to other customers
• Commitments to exclude customer data from training by default

Risk Assessment

The available information does not establish whether the amendment creates additional legal or commercial risk. The statement that approximately 2,807 words were added is not a substitute for the actual text and does not show whether the additions are favorable, neutral, or adverse.

Information Needed

Please provide the full redline or the actual additions, deletions, and replacements using the stated notation. The analysis can then identify the material changes, explain their practical effect, and highlight any provisions permitting or restricting the use of customer data for AI-model training.

Summary of Important Changes

1. AI-model training

• The diff contains no express provision authorizing Litmus to use customer data to train, fine-tune, evaluate, or improve generative-AI or other machine-learning models.
• The former language allowed use of collected information for:
• internal evaluations and statistical analysis;
• monitoring service performance;
• understanding visitor and user behavior;
• improving services;
• market research; and
• developing new features and functionalities.
• Those specific purposes appear to be replaced with broader or more limited wording, including use of “similar tools,” cookie-related processing, legal compliance, dispute resolution, and enforcement.
• Risk: Although the revised text does not clearly permit AI training, the remaining broad references to improving services, analytics, aggregated data, service providers, and business purposes could potentially be asserted as covering model development. The policy should expressly state whether customer content, Email Submissions, email analytics data, or personal data may be used for AI training, whether data is de-identified, whether customer consent or an opt-out is available, and whether third-party AI providers may receive the data.

2. Expanded or clarified data-sharing disclosures

The revised policy adds or preserves detailed categories of potential disclosures, including:

• service providers and subprocessors;
• organizations controlling a user’s email domain, such as an employer;
• billing contacts;
• affiliated businesses and third-party services;
• business purchasers or successors;
• authorities and other parties for legal, fraud-prevention, security, or enforcement purposes.

Risk: Customer data may be disclosed to a broader range of recipients, particularly employers, billing contacts, affiliates, service providers, and business transferees. The policy does not appear to provide a comprehensive recipient list in the text itself, instead referring users to separate materials such as a subprocessors list.

3. Profiling and third-party data enrichment

The revised language permits Litmus to combine information from or about users obtained from third-party sources with information already held by Litmus to create user profiles and make marketing and sales efforts more relevant and personalized.

Risk: This enables broader profiling, behavioral analysis, and targeted marketing. The scope, sources, retention period, and user controls for this profiling are not fully specified.

4. Retention and deletion

The policy now states that data is generally retained while an account remains active, or as needed for legal obligations, disputes, and enforcement. It also states that aggregated or de-identified data may continue to be used after deletion.

Risk: Account cancellation or deletion may not eliminate derived, aggregated, or de-identified information. The policy does not define the de-identification standard.

5. Children’s data and Email Analytics

The revised policy prohibits use of Email Analytics Services for information concerning persons under 13, subject to a narrow parent-authorized exception, and allows deletion without notice if such data is discovered.

Risk: Customers using email analytics must implement their own screening and compliance controls; responsibility is effectively placed on the customer.

6. Policy changes

The revised policy permits updates by website or in-application posting. Unless the user terminates within 10 days, the revised policy applies immediately to continued or new use.

Risk: Continued use may constitute acceptance of materially expanded data uses, including future uses not currently described.

Summary

The provided diff contains only the statement:

> “Added approximately 2807 words to the document”

No actual contractual language, additions, deletions, or replacements were provided. As a result, it is not possible to identify the legal or commercial impact of the changes.

AI Training and Data Use

The diff does not include enough text to determine whether the contract now permits the provider to:

• Use customer data, prompts, outputs, or content to train or improve AI models;
• Use customer data for human review, quality assurance, or product development;
• Retain or reuse data after termination;
• Combine customer data with data from other customers;
• Create aggregated, anonymized, or de-identified datasets;
• Allow subcontractors or third-party AI providers to access customer data;
• Opt the customer out of model training or other secondary uses; or
• Claim ownership or broad usage rights over customer inputs or generated outputs.

Other Risks That Cannot Be Assessed

The missing text also prevents review of potential changes involving:

• Confidentiality and data-security obligations;
• Privacy-law compliance and international data transfers;
• Intellectual-property ownership and licenses;
• Indemnities and liability caps;
• Warranties and disclaimers;
• Data retention, deletion, and return;
• Audit rights and compliance obligations;
• Suspension, termination, or unilateral amendment rights; and
• Subcontracting or assignment.

Required Information

Please provide the actual redlined language, including the text shown in {additions}, [deletions], and []{replacements}. The statement that approximately 2,807 words were added is not sufficient to evaluate the changes or identify new risks.

Summary of Important Changes and Risks

1. AI model training

• The diff does not expressly authorize or prohibit using customer data to train AI models.
• References to using information for “market research” and to “develop new features and functionalities” were removed and replaced with purposes such as legal compliance, dispute resolution, and enforcing agreements.
• The revised language still permits use of information to analyze and measure website/user behavior, improve services, and use “similar tools.” Depending on how broadly “improve our Services” is interpreted, this could potentially include analytics or AI development, but it is not clear enough to establish a specific AI-training right.
• The policy should expressly state whether customer content, email submissions, analytics data, or derived/de-identified data may be used to train, fine-tune, evaluate, or otherwise improve AI models; whether data is used for internal or third-party models; and whether customers may opt out.

2. Broader and more detailed disclosure permissions

The revised policy adds or clarifies numerous categories of permitted disclosures, including:

• Service providers supporting hosting, payment processing, web chat, email services, analytics, and general business operations.
• Organizations controlling a user’s email address, such as an employer, and billing contacts.
• Other users and the public, where users post profile information or content in public areas.
• Affiliated businesses and third-party services.
• Purchasers or successors in business transfers, mergers, bankruptcy, or asset sales.
• Government authorities, courts, and other recipients where disclosure is believed necessary to comply with law, protect rights or safety, prevent fraud, or enforce agreements.

Risk: Customer data may be disclosed to a wider range of recipients and transferred in corporate transactions. Publicly posted content may be collected and reused by others, outside Litmus’s control.

3. Retention and deletion

• Retention is now described as generally lasting for the duration of the account, or longer where needed for legal obligations, disputes, or enforcement.
• After deletion, Litmus may continue using aggregated or de-identified data derived from personal data.
• Account cancellation may end access to account information and uploaded data, but does not necessarily require immediate deletion.

Risk: “De-identified” data may remain available indefinitely, and the policy does not specify detailed deletion timelines.

4. International transfers and security

• The revised policy adds U.S.-based processing, international processing, Data Privacy Framework reliance, contractual safeguards, and Standard Contractual Clauses.
• It expressly states that complete security cannot be guaranteed and gives users responsibility for protecting account credentials.

5. Children’s data

• The revised language more clearly prohibits use by individuals under 13 and prohibits providing Email Analytics data concerning children under 13, subject to limited parental authorization.

6. Policy changes

• Litmus may update the policy by posting revised terms online or in the application.
• The changes become effective immediately unless the user terminates the account within 10 days.

Risk: Continued use may constitute acceptance of significant future changes, including changes to data-use practices.

Summary

Key Limitation

The supplied diff does not include the actual contractual language. It only states:

> “Added approximately 2807 words to the document”

Without the added text, it is not possible to identify:

• Changes to customer data rights or permitted uses
• Whether customer data may be used to train, fine-tune, test, or improve AI models
• Whether data is anonymized, aggregated, de-identified, or retained
• Any new data-sharing, confidentiality, security, or subprocessors provisions
• Changes to ownership, licensing, or intellectual-property rights
• New liability limitations, indemnities, audit rights, or termination consequences
• Whether the new language applies retroactively to previously collected data

AI-Training Risk Assessment

No conclusion can be reached about AI-model training because the relevant contractual additions are not provided. The added language should be reviewed specifically for terms such as:

• “train,” “fine-tune,” “improve,” “develop,” or “optimize” models
• “machine learning,” “artificial intelligence,” or “generative AI”
• “customer data,” “content,” “inputs,” “outputs,” or “usage data”
• “de-identified,” “aggregated,” or “anonymized” information
• Rights to use data after termination or indefinitely
• Sharing data with affiliates, vendors, or model providers
• Opt-out, deletion, retention, or customer-control mechanisms
• Statements that model outputs or trained models may be retained despite deletion requests

Information Needed

Please provide the full redline showing the actual additions, deletions, and replacements. Once provided, the changes can be analyzed for:

1. Business impact

2. Customer-data usage

3. AI-training permissions

4. Privacy and confidentiality risks

5. Intellectual-property consequences

6. Recommended negotiation points

Executive Summary

The diff appears to replace a relatively short description of data use with a substantially expanded privacy policy. It adds detailed disclosures about sharing, retention, children’s data, international transfers, user rights, cookies, security, and policy changes. The formatting is heavily corrupted, so the final wording should be checked against the clean source document before adoption.

Important Changes and Risks

1. AI model training

• No express authorization to use customer data to train AI models is visible in the diff.
• The revised language removes or changes references to:
• “internal evaluations”
• “statistical analysis”
• “market research”
• “develop new features and functionalities”
• The new language refers more generally to analyzing information, measuring visitor behavior, improving services, using cookies or similar tools, and aggregating usage information.
• These provisions could potentially support product improvement or analytics activities, but they do not clearly state whether customer content, email submissions, or other account data may be used to train, fine-tune, test, or evaluate artificial-intelligence or machine-learning models.
• If AI training is intended, the policy should expressly address:
• Which customer data may be used;
• Whether data is de-identified or aggregated;
• Whether inputs or outputs are retained;
• Whether third-party AI providers receive the data;
• Whether data is used to train general-purpose models or only customer-specific systems;
• Opt-out or objection rights; and
• Deletion and model-retention limitations.

2. Broader and more detailed third-party sharing

The revision expressly permits sharing with service providers for hosting, payment processing, web chat, email services, analytics, and other business operations. It also adds disclosures concerning:

• Organizations controlling a user’s email domain;
• Billing contacts;
• Affiliates and third-party services;
• Business transfers, acquisitions, bankruptcy, and asset sales;
• Fraud prevention, credit-risk reduction, legal requests, and protection of Litmus or others.

Risk: Customer data may be disclosed to a wider range of parties and transferred in corporate transactions, subject to broad exceptions and potentially changing subprocessors.

3. Expanded profiling and marketing use

The policy adds the ability to combine information from third-party sources with information held by Litmus to create user profiles and make marketing and sales efforts more relevant or personalized.

Risk: This increases profiling and behavioral-advertising concerns and may trigger additional consent, notice, opt-out, or data-sale/share obligations under applicable privacy laws.

4. Retention and deletion

The revision states that data is generally retained while an account exists, or longer when needed for legal obligations, disputes, or enforcement. It also preserves aggregated or de-identified data after deletion and warns that some information may remain in records.

Risk: Deletion rights are limited, and the policy does not specify concrete retention periods.

5. Children’s data

The revision prohibits use by children under 13 and restricts customers from providing information concerning such children through Email Analytics Services, subject to limited parental authorization language.

6. Unilateral policy changes

Litmus may update the policy by posting changes online or in the application. The revised policy takes effect immediately for continued use unless the user terminates the account within 10 days.

Risk: Continued use may constitute acceptance of material changes, including future data-use practices.

Summary

The supplied diff states only:

> “Added approximately 2,807 words to the document”

It does not include the actual added, deleted, or replaced language. As a result, the legal and commercial impact cannot be reliably assessed.

AI Training and Customer Data

• No specific language is provided regarding whether the customer’s data may be:
• Used to train, fine-tune, or improve AI models;
• Used to train models for other customers or the provider generally;
• Retained after termination;
• Combined with other customer data;
• Reviewed by humans for model improvement or safety;
• Anonymized, de-identified, or aggregated before use; or
• Excluded from training by default or only upon opt-out.

• Because the added language is unavailable, it is not possible to determine whether the changes introduce or expand any rights to use customer data for AI training.

Other Legal Risks That Cannot Be Assessed

The missing text prevents review of potential changes concerning:

• Data ownership and license scope;
• Confidentiality and permitted disclosures;
• Privacy, security, and regulatory compliance;
• Data retention and deletion;
• Subprocessors and third-party model providers;
• Intellectual-property ownership in outputs or model improvements;
• Indemnities and limitations of liability;
• Warranties and disclaimers;
• Audit rights and compliance obligations;
• Suspension, termination, and post-termination data handling; and
• Governing law or dispute-resolution provisions.

Required for Further Analysis

Please provide the actual redlined text, including:

• Additions in {};
• Deletions in []; and
• Replacements in []{}.

Without the underlying wording, the only reliable conclusion is that the document became approximately 2,807 words longer; the legal significance of those additions remains unknown.

Summary

The diff indicates that approximately 2,807 words were removed from the document. However, no information identifies which provisions were deleted or whether any replacement language was added.

Key Legal Implications

• Substantive changes cannot be determined: The deleted text could relate to liability, confidentiality, data protection, intellectual property, warranties, termination, governing law, or other material terms.
• Risk may have shifted: Removing customer-protective provisions could increase the customer’s exposure. Conversely, deleting provider-favorable language could reduce the provider’s rights or obligations.
• Potential loss of protections: Deleted provisions may have included security commitments, audit rights, data-return or deletion obligations, indemnities, limits on data use, or restrictions on subcontractors.
• Internal inconsistency risk: If the removed language contained definitions, cross-references, exceptions, or conditions, its deletion may create ambiguity or leave other provisions incomplete.

AI Training and Customer Data

The supplied diff does not show the deleted text, so it is not possible to determine whether the changes:

• Permit or prohibit using customer data to train, fine-tune, or improve AI models;
• Change whether customer prompts, inputs, outputs, or account data may be used for training;
• Remove consent, opt-out, or notice requirements;
• Expand use of data in aggregated, de-identified, or anonymized form;
• Change ownership or licensing rights in customer data, outputs, or model improvements; or
• Modify retention, deletion, security, or confidentiality obligations relating to AI data.

Because the deleted material could have contained restrictions on AI training, its removal may create a material but unquantifiable risk that customer data can be used more broadly—although this cannot be concluded from the available information alone.

Recommended Next Step

Provide the actual redline, including the deleted language and any replacement text. The deletion-only notation is insufficient to assess the legal effect or identify changes concerning AI training and customer-data use.

Summary

The provided diff does not include the actual amended legal language. It only states:

> “Added approximately 2807 words to the document”

Because the additions, deletions, and replacements are not shown, it is not possible to reliably identify:

• Changes to rights or obligations
• New liability, indemnity, confidentiality, or termination risks
• Changes to data ownership or licensing
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models
• Whether such use is subject to consent, opt-out rights, anonymization, aggregation, or customer-specific restrictions
• Any changes to security, retention, subprocessors, or cross-border data transfers

AI Training and Data-Use Assessment

No conclusion can be drawn about AI-model training from the supplied material. The statement that approximately 2,807 words were added does not reveal whether the new provisions:

• Permit use of customer content, prompts, inputs, outputs, or telemetry for model training;
• Allow use by the provider, its affiliates, or third-party service providers;
• Distinguish between personal data, confidential information, and de-identified or aggregated data;
• Make training use automatic, consent-based, or subject to an opt-out;
• Apply to historical data or only data submitted after the amendment;
• Permit retention of data for training after contract termination; or
• Limit the provider’s responsibility for models trained using customer data.

Information Needed

Please provide the full marked-up text, including:

• Additions in {braces};
• Deletions in [brackets]; and
• Replacements in []{} format.

Once the substantive diff is provided, the changes can be analyzed for legal effect and specific risks, including any provisions allowing customer data to be used to train or improve AI models.

Summary of Changes

Scope of the Diff

• The diff states that approximately 2,807 words were removed from the document.
• However, the actual deleted language is not included. The diff therefore does not identify which provisions were removed or what replacement terms, if any, apply.

Data Use and AI Training

• No reliable conclusion can be reached about AI-training rights from the information provided.
• The deleted text may have contained provisions addressing:
• Whether customer data may be used to train, fine-tune, or improve AI models;
• Whether prompts, inputs, outputs, or usage data are retained;
• Whether data is anonymized, aggregated, or shared with affiliates or service providers;
• Whether the customer can opt out of model training;
• Ownership and permitted uses of customer data and generated outputs; or
• Security, confidentiality, and deletion obligations.
• If any restrictions on AI training were removed, the customer may face an increased risk that its data, prompts, or outputs can be used for product development or model improvement.
• If disclosure or consent language was removed, the revised document may provide less transparency or fewer control rights, even if broader data-use rights remain elsewhere in the agreement.
• Conversely, the removal could have eliminated permissive language and narrowed the provider’s rights. The direction of the change cannot be determined without the actual text.

Other Potential Legal Risks

The deleted provisions may also have addressed important terms such as:

• Data protection and regulatory compliance;
• Confidentiality and permitted disclosures;
• Intellectual-property ownership and licensing;
• Liability limitations and indemnities;
• Warranties and disclaimers;
• Data retention, deletion, and return;
• Security incident notification;
• Audit rights; and
• Termination effects and survival of obligations.

Removing these provisions could create ambiguity, reduce customer protections, or cause fallback language elsewhere in the contract to control.

Recommended Follow-Up

• Obtain the full before-and-after versions or the redlined text.
• Specifically compare sections concerning customer data, machine learning, artificial intelligence, model training, service improvement, confidentiality, security, and intellectual property.
• Confirm whether any deletion is offset by new language elsewhere in the agreement.
• Until reviewed, treat the AI-training position as unknown, rather than assuming that customer data is excluded from training.

Summary

The provided diff only states:

> “Added approximately 2807 words to the document”

It does not include the actual added language or identify which provisions changed. As a result, it is not possible to reliably assess:

• New legal obligations or rights
• Changes to liability, indemnification, warranties, or termination
• Changes to confidentiality or data-protection obligations
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models
• Whether such use requires consent, is automatic, or can be opted out of
• Whether data is anonymized, aggregated, retained, or shared with third parties
• Whether the customer receives notice or control over model-training activities

AI Training and Data-Use Changes

No specific AI-training or data-use provisions are visible in the supplied material. The statement that approximately 2,807 words were added does not establish whether customer data may be:

• Used to train or improve artificial-intelligence or machine-learning models
• Used for product development, analytics, or service improvement
• Reviewed by humans or disclosed to service providers
• Combined with other customers’ data
• Retained after termination
• Subject to an opt-out or deletion right

Risk Assessment

The principal risk is informational: the actual contractual changes are missing, so material new rights or obligations may be overlooked. In particular, an added data-use clause could significantly expand the provider’s rights to use customer content beyond providing the contracted services.

Information Needed

Please provide the complete diff, including the text inside the addition markers ({...}), deletion markers ([...]), and replacement markers ([...] {...}). The full language is necessary to identify the precise legal effect and any new risks, especially those involving AI-model training and customer data.

Structured Summary of Important Changes

1. Major restructuring of the Privacy Policy

The amendment replaces much of the prior narrative privacy language with a reorganized, numbered policy addressing:

• Data sharing
• Security
• User choices and privacy rights
• Cookies
• Data retention
• Children’s privacy
• Data Privacy Framework compliance
• Policy changes and contact information

The revised language appears to be a substantial rewrite rather than a limited clarification.

2. Use of customer data

Removed or narrowed stated purposes

The prior language expressly stated that Litmus used collected information for:

• Internal evaluations and statistical analysis
• Monitoring Service performance
• Measuring visitor and User behavior and trends
• Market research
• Developing new features and functionalities
• Enforcement of the Terms of Service

Much of this language is removed or replaced with more general purposes, including:

• Complying with legal obligations
• Resolving disputes
• Enforcing agreements
• Supporting general business operations
• Marketing and business-related purposes
• Usage analytics and website improvement

This may reduce specificity about how customer data is used and make the permitted purposes broader or less transparent.

3. AI-model training

No express provision concerning artificial intelligence, machine learning, generative AI, model training, model improvement, or use of customer content to train AI models appears in the provided diff.

Accordingly:

• The amendment does not clearly authorize AI training.
• It also does not expressly prohibit training on customer data.
• Broad language concerning “business-related purposes,” “usage information,” analytics, service improvement, and aggregated or de-identified data could potentially be argued to cover model development if Litmus later treats AI development as a business or product-improvement activity.
• The absence of an explicit restriction leaves uncertainty, particularly regarding Email Submissions, uploaded content, and other customer-provided material.

Customers should seek a written clarification that customer content and personal data will not be used to train or fine-tune AI models, unless expressly authorized.

4. Expanded and clarified third-party sharing

The revised policy expressly addresses sharing with:

• Service providers and subprocessors
• Organizations associated with a user’s email domain
• Billing contacts
• Affiliated businesses and third-party services
• Business-transfer purchasers
• Fraud-prevention and credit-risk organizations
• Government authorities and legal-request recipients

Although service providers are said to be contractually limited to providing services, the policy permits broad categories of disclosure and international processing.

5. Retention and deletion

The revised policy states that data is generally retained while an account remains active, or as needed to:

• Comply with law
• Resolve disputes
• Enforce agreements

It also preserves Litmus’s ability to retain aggregated or de-identified data after deletion and notes that some information may remain in records after account deletion.

6. Policy-change mechanism

Litmus may update the Privacy Policy by posting changes online or in the application. The new terms take effect immediately and apply to continued use unless the customer terminates the account within 10 days.

This creates a material risk that continued use will be treated as acceptance of expanded data practices.

7. Children’s data

The policy strengthens the restriction on users under 13 and prohibits customers using Email Analytics Services from providing information relating to children under 13, subject to limited parental authorization language.

8. International transfers and rights

The revised policy adds detailed Data Privacy Framework, SCC, international-transfer, GDPR, CCPA/CPRA, access, deletion, objection, and consent-preference provisions. These additions improve procedural clarity but do not necessarily limit the substantive scope of permitted processing.

Summary of Important Changes

1. Expanded purposes for using personal information

The revised policy substantially expands and reorganizes the purposes for which Litmus may use collected information. New purposes include:

• Creating and administering user accounts.
• Providing customer support, troubleshooting, billing assistance, and account management.
• Monitoring Service performance and conducting statistical analysis.
• Analyzing visitor and user behavior and trends.
• Understanding how the Services are used.
• Improving existing Services and developing new features and functionalities.
• Conducting market research.
• Enforcing the Terms of Service and governing subscription agreements.
• Preventing fraud and illegal, abusive, or undesirable activity.
• Sending transactional communications, which users cannot opt out of.
• Creating user profiles and combining information from third-party sources to improve marketing, sales efforts, personalization, and user experience.
• Maintaining system and account security and responding to legal requests.

Risk: These purposes are broader than the prior language, particularly for analytics, product development, profiling, marketing, and combining third-party information. “Improve” and “develop” are not narrowly defined.

2. AI-model training

The diff does not expressly authorize using customer data to train, fine-tune, or evaluate artificial intelligence or machine-learning models. There is no clear reference to “AI,” “machine learning,” “training data,” or similar language.

However, the following new language could create ambiguity or future risk:

• Use of information for “statistical analysis,” “market research,” and developing new features and functionalities.
• Use of visitor and User behavior and trends to improve Services.
• Use of aggregate or de-identified data for marketing and other business purposes, including after deletion.
• Broad references to advances in technology and changes to data-collection practices.

Risk: Although not an explicit AI-training grant, Litmus might argue that model development or evaluation falls within product improvement, statistical analysis, or aggregated/de-identified use. Customers seeking to prohibit AI training should request an express restriction covering customer content, Email Submissions, personal information, metadata, prompts, outputs, and derived data.

3. Broader sharing and disclosure

The policy adds or clarifies disclosure to:

• Service providers, including payment processors, hosting providers, web-chat providers, email providers, and web-traffic analytics providers.
• An organization controlling a user account, including disclosure of the user’s email address and account information.
• Billing contacts upon request.
• Other users through public profiles, forums, messages, uploaded content, and other public areas.
• Affiliates, third-party services, business purchasers, and authorities responding to legal requests.

Service providers are stated to be limited to necessary uses and subject to contractual and technical protections, but the categories of providers and permitted operational purposes are broad.

4. Data transfers and retention

The policy confirms hosting and processing in the United States and potentially other countries, with reliance on the Data Privacy Framework, SCCs, and related transfer mechanisms.

Deletion rights are qualified: some information may remain in records, and aggregated or de-identified data may continue to be used after deletion.

Summary of Changes

Overall Change

• Approximately 2,807 words were removed from the document.
• No replacement text or additions were provided, so the specific legal provisions removed cannot be identified from the diff alone.

Customer Data and AI Training

• The diff does not show whether any express provisions concerning AI training were added, removed, or modified.
• However, because a substantial amount of text was deleted, the removed material may have included terms addressing:
• Whether customer data may be used to train, fine-tune, or improve AI models;
• Whether customer prompts, inputs, outputs, or other content are retained;
• Whether data is anonymized, aggregated, or de-identified before use;
• Opt-out, consent, or customer-control mechanisms;
• Restrictions on using confidential or personal information for model training;
• Ownership or licensing rights in customer data and AI-generated outputs;
• Security, deletion, and data-retention obligations; and
• Disclosure of third-party AI providers or subprocessors.

Key Risks

• Loss of protections: If deleted language restricted the provider’s use of customer data, its removal could expand permitted data use, potentially including AI training or product improvement.
• Reduced transparency: Deletion of disclosure or consent provisions could make it less clear how customer data is handled.
• Weaker confidentiality or privacy safeguards: Removed limitations may have governed sensitive, personal, or confidential information.
• Changed commercial position: Deleting data-use, ownership, indemnity, or liability terms could materially shift risk to the customer.
• Interpretation risk: If the remaining document still authorizes broad use of data, the deletion could have significant practical effect even without an express AI-training clause.

What Cannot Be Determined

• The actual legal effect cannot be confirmed without the text that was removed and the remaining document.
• The diff does not establish whether AI-training rights were narrowed, expanded, or left unchanged.

Recommended Review

Compare the prior and revised versions specifically for sections titled “Data,” “Customer Content,” “Confidentiality,” “Privacy,” “Machine Learning,” “AI,” “Service Improvement,” “Subprocessors,” and “License.” Confirm whether the revised agreement expressly states that customer data will not be used to train AI models, or provides a clear opt-out and deletion mechanism.

Summary

The provided diff does not include the actual amended contract language. It only states:

> “Added approximately 2807 words to the document”

Accordingly, it is not possible to identify:

• Which provisions were added, deleted, or replaced;
• New legal, financial, operational, or liability risks;
• Changes to data ownership, confidentiality, privacy, or security obligations;
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether such use is subject to consent, opt-out rights, anonymization, aggregation, or customer instructions; or
• Whether the provider may share customer data with affiliates, subprocessors, or third-party model providers.

Information Needed

Please provide the actual redlined text, using the stated notation:

• {added text}
• [deleted text]
• []{replacement text}

The AI-training provisions should be reviewed particularly for language addressing:

1. Permitted data use — whether customer content may be used for model training or product improvement.

2. Scope of data — whether “customer data” includes prompts, outputs, metadata, telemetry, or personal information.

3. Consent and control — whether use is automatic, opt-out, or opt-in.

4. De-identification — whether data must be anonymized or aggregated before use.

5. Retention and deletion — how long training data is retained and whether deletion requests apply to derived models.

6. Third-party access — whether data may be disclosed to subprocessors or external AI providers.

7. Ownership and license — whether the provider receives a broad, perpetual, worldwide, royalty-free license.

8. Confidentiality and security — whether training use is consistent with confidentiality commitments and applicable privacy laws.

9. Model outputs and memorization — allocation of risk if customer information appears in outputs or is reproduced for other users.

10. Changes over time — whether the provider can change its data-use practices without notice or renewed consent.

Actual contract language is required for a substantive legal-risk analysis.