Microsoft 365 Copilot, now named Microsoft Copilot

The document exists. The ledger fetched it at its publisher and quotes it.

Record ID

AVD-2026-0013

Kind

Business tier

Jurisdiction

United States

Last verified

15 September 2026

Added

15 September 2026

• Prompts, responses and data accessed through Microsoft Graph are not used to train foundation large language models.
• European Union traffic stays within the EU Data Boundary, while worldwide traffic can be sent to the EU and other regions for model processing.
• Models provided by Anthropic as a subprocessor are excluded from the EU Data Boundary.
• Abuse monitoring including human review of content is available in Azure OpenAI, and Microsoft Copilot services have opted out of it.

Used for training by default, Retention period, Deletion on request, Storage region and residency, Subprocessor list published, Human review of content, Opt out available, DPA available, Persistent memory across sessions, Last change to the terms. Stated means the document you can open below says it; silent means the ledger read the document and it does not.

Used for training by defaultStated

No. Prompts, responses and data accessed through Microsoft Graph are not used to train foundation models, and optional customer feedback is excluded too.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Retention periodStated

Interaction content is stored as Copilot activity history, encrypted, and governed by the Purview retention policies the admin sets. No fixed vendor period is printed.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Deletion on requestStated

Users delete their own Copilot activity history, including prompts and responses, from the My Account portal.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Storage region and residencyStated

EU traffic stays within the EU Data Boundary and other traffic may be processed in the United States, the EU or elsewhere. One named model subprocessor is excluded from the boundary.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Subprocessor list publishedStated

Named rather than listed. Anthropic and OpenAI are identified as model subprocessors, each with its own page describing the terms that apply.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Human review of contentStated

None on this service. Abuse monitoring including human review is available in Azure OpenAI and Microsoft Copilot services have opted out of it.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Opt out availableSilent

Nothing to opt out of on training, because there is no training use. Admin controls cover feedback and connected experiences instead.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

DPA availableStated

Residency commitments are stated as coming from the Microsoft Product Terms and the Data Protection Addendum.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Persistent memory across sessionsSilent

No memory feature is described. The page describes working context and an activity history rather than a persistent memory store.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

Last change to the termsStated

The page prints no effective line in its body. Its document metadata carries a date of 9 July 2026 and a last update of 18 August 2026.Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, 18 August 2026.

1. 2,024 year

   Date Copilot became a covered workload in the Product Terms residency commitments

   Microsoft Learn, data, privacy and security for Microsoft Copilot, primary source, as of 9 July 2026.

The EU Data Boundary is the selling point and the exception is the thing to write down: models from one named third party subprocessor sit outside it. A European organisation that chose this product for the boundary has to decide, as an administrator, whether to enable those models, because enabling them moves that traffic out of the commitment the rest of the service makes.

1. Microsoft Learn, data, privacy and security for Microsoft CopilotPrimary · 18 August 2026

• VerifiedConsumer tierAVD-2026-0012

  Microsoft Copilot on a personal account

  United States · verified 15 September 2026

  Microsoft states that except for certain categories of users or users who have opted out, it uses data from Bing, MSN, Copilot and ad interactions for AI training.

• VerifiedAPI and platformAVD-2026-0014

  Azure OpenAI Service and models sold by Azure in Microsoft Foundry

  United States · verified 15 September 2026

  The models are stateless, no prompts or completions are stored in the model, and prompts and completions are not used to train, retrain or improve the base models.

• VerifiedBusiness tierAVD-2026-0009

  Gemini for Google Workspace

  United States · verified 15 September 2026

  Google states Workspace does not use customer data for training models without the customer's prior permission or instruction.

• VerifiedAPI and platformAVD-2026-0026

  Amazon Bedrock

  United States · verified 15 September 2026

  Amazon Bedrock uses a zero data retention security model, so by default it does not store model inputs or outputs.

• VerifiedBusiness tierAVD-2026-0025

  GitHub Copilot Business and Enterprise

  United States · verified 15 September 2026

  GitHub states it does not use Copilot Business or Copilot Enterprise customer data to train AI models.

• VerifiedBusiness tierAVD-2026-0024

  Cursor and its privacy mode

  United States · verified 15 September 2026

  The terms of service state that Cursor will not use content to train any AI models unless you have explicitly agreed.