Not legal advice · Summaries of vendors' public pages, which change often. Verify with the vendor and your contract before relying on anything here.

Does Copilot train on your data? Personal vs Microsoft 365

Copilot has different data terms on personal and business plans. Personal: Microsoft Copilot app (web, desktop, mobile) signed in with a personal Microsoft account. Business: Microsoft 365 Copilot. Every value links to Microsoft's own page. Last verified .

Personal plan

Microsoft Copilot (personal Microsoft account)

Depends on app version

Training default depends on which Copilot app version you use.

Full personal-plan page →
Business plan

Microsoft 365 Copilot

Doesn't train

Doesn't train on business data by default.

Full business-plan page →
Summary of Microsoft's public pages. Not legal advice: terms vary by plan and contract and can change. Confirm with Microsoft before relying on it.

Side by side

What we checkedPersonal Microsoft Copilot (personal Microsoft account)Business Microsoft 365 Copilot
Trains on your data by default Depends on app version

Microsoft says the new Copilot app (from Aug 18 2026, and Copilot on the web) does not use prompts, responses or files to train foundation models. The older app's FAQ says signed-in adult users' conversations are used for AI training unless they opt out. Note that "foundation models" is narrower than "any model".

No

Prompts, responses, and Microsoft Graph data aren't used to train foundation LLMs.

Can you turn training off? Older app: yes. New app: no training toggle needed or listed

Older app: Profile > Privacy > Training on conversation activity / Training on voice conversations. The new app's privacy-controls page lists Memory, Shared experiences, Chat history, Web search, Personalized ads, and Edge import, with no training setting.

Not tracked for business plans
Data retention Older app: 18 months by default. New app: unknown

The new-app pages checked describe how to delete chats but give no retention period.

Admin-configurable

Interaction history is stored; admins set retention via Microsoft Purview.

Retention after you delete Unknown

No post-deletion purge window found on the Copilot pages checked (old or new app).

Not tracked for business plans
Human review of chats Older app: yes, no opt-out. New app: feedback reviewed; otherwise unknown

Older-app FAQ: some conversations get automated and human review for product improvement and safety, with no opt-out. The new-app Transparency Note says submitted feedback is reviewed by Microsoft's operations teams.

Not tracked for business plans
Temporary / incognito chat Unknown

No temporary or incognito chat mode is described on the consumer Copilot pages checked.

Not tracked for business plans
Data location / residency Your region, the US, and other Microsoft locations

From the general Microsoft Privacy Statement. Nothing Copilot-specific found.

Source: microsoft.com/en-us/privacy/privacystatement (checked Oct 17, 2026)
Yes

EU Data Boundary and data residency commitments; LLM calls may route to other regions for capacity.

SOC 2 Type II Not checked yet

Not checked in this personal-plan research pass (consumer/business compliance docs not reviewed).

Unknown

Not stated on the Copilot privacy pages checked.

ISO/IEC 42001 Not checked yet

Not checked in this personal-plan research pass (consumer/business compliance docs not reviewed).

Yes

Listed: ISO 42001 standard for AI management systems.

DPA available Not checked yet

Not checked in this personal-plan research pass (consumer/business compliance docs not reviewed).

Yes

Covered by the Microsoft Products and Services DPA.

BAA / HIPAA Not checked yet

Not checked in this personal-plan research pass (consumer/business compliance docs not reviewed).

Yes

Supports HIPAA compliance for properly configured implementations (web search queries excluded).

Zero-retention option Not checked yet

Not checked in this personal-plan research pass (consumer/business compliance docs not reviewed).

Unknown

Not stated on the Microsoft pages we checked.

Verbatim quotes from each source are on the personal and business pages.

How to turn off training on a personal Copilot account

New app (Aug 18 2026+): Microsoft says chats aren't used to train foundation models, so there's no toggle. Older app: turn off "Training on conversation activity". Step-by-step instructions →

See also: Why AI training on your data matters · How we source and verify this