UAE Companies Can Use Customer Data in ChatGPT with PDPL Compliance

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UAE companies can generally process customer data using ChatGPT, but compliance depends on three controllable factors: plan tier selection, physical data residency, and contract terms. Since November 2025, OpenAI has offered UAE data residency for Enterprise, Edu, and API platforms, addressing data sovereignty concerns. The legal framework is established by Federal Decree-Law No. 45 of 2021, which mandates consent, data minimization, and processor due diligence. Organizations must implement operational procedures rather than rely on legal ambiguity when using AI tools with personal data.

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