OpenAI specified that, as far as European (EEA and Swiss) developers were concerned, their Agreement is with OpenAI Ireland Ltd. OpenAI stopped acting as a separate controller of personal data, and developers now have to present a privacy notice to their users prior to processing their data.
OpenAI also extended export restrictions to plugins “located” in countries embargoed or sanctioned by the US. This provision previously concerned only plugin owners.
OpenAI Ireland Ltd is a Dublin-based subsidiary of OpenAI set up in 2023.