In this guide · 8 sections
- 01Free vs paid AI API data use, compared
- 02Why Singapore businesses are not covered by the EU exception
- 03How free prototypes end up leaking customer data
- 04How to check which tier your tools are on
- 05Switching a prototype to paid, no-training terms
- 06When a free tier is fine
- 07Do it yourself or get help?
- 08Frequently asked questions
Short answer
Yes for some providers. Google's Gemini API free tier and Mistral's free Studio plan may use your prompts to improve their models, and Google says humans may review them. OpenAI and Anthropic APIs don't train on your data by default, unless you opt in, such as OpenAI's free-tokens data sharing offer.
Free vs paid AI API data use, compared
Each provider's terms decide what happens to the text, files and images your app sends. The table summarises the main ones as of 19 October 2026. Terms change, so re-read the linked pages before you build.
| Provider | Free use | Paid API default | Source |
|---|---|---|---|
| Google Gemini API | Unpaid quota and AI Studio: content used to improve Google products; human review possible | Prompts and responses not used to improve products; logged for a limited time for abuse checks | Gemini API terms, effective 23 March 2026 |
| OpenAI API | No free tier as such; free daily tokens only if you opt in to share traffic | Not used for training unless you opt in | Your data, data sharing help |
| Anthropic API | Not applicable (commercial terms) | Not used for training by default; feedback you submit may be | Anthropic privacy centre, updated 18 August 2026 |
| Mistral API (Studio) | Free mode: input and output may be used to train models | Pay-as-you-go: you can opt out via the Anonymous improvement data toggle; Enterprise opted out by default | Mistral help centre |
Google's terms are the clearest example. For unpaid services, Google says it uses the content you submit and the responses "to provide, improve, and develop Google products and services and machine learning technologies", that human reviewers may read, annotate and process API input and output after it is disconnected from your account, and: "Do not submit sensitive, confidential, or personal information to the Unpaid Services."
Why Singapore businesses are not covered by the EU exception
Google's terms say that if you are in the European Economic Area, Switzerland or the UK, the paid-service data rules apply to all services, including free ones. Developers sometimes read blog posts written for those regions and assume free usage is safe everywhere. Singapore is not in that list, so the unpaid rules apply to a Singapore business on the free tier.
The same terms define when you are "paid": Gemini API access is a paid service only when you call it through a Google Cloud project with an active billing account. A key created in AI Studio on a project without billing is on the unpaid terms, however many tokens you use.
How free prototypes end up leaking customer data
The leak is rarely a decision. It usually happens like this: a staff member or freelancer builds a quick tool with a free key, it works, people start using it, and nobody revisits the key or the account it belongs to.
- A WhatsApp or website chatbot answers customer questions, so customers' names, phone numbers and complaints flow through the free tier.
- An email summariser reads the shared inbox, including invoices and contract terms.
- A form or OCR tool extracts details from uploaded documents such as IDs, payslips or medical memos.
- The free key sits in a freelancer's personal account, so the business can't see the settings, logs or bill.
Under the PDPA, your business remains responsible for personal data it sends to a provider, and your privacy notice should describe how it is used. The PDPC's Advisory Guidelines on Use of Personal Data in Generative AI (published 20 July 2026) treat a business that uses an AI system as a deployer with primary responsibility for PDPA compliance; our summary of the guidelines explains what that means. Sending customer messages to a service whose terms allow product improvement and human review is hard to square with that.
How to check which tier your tools are on
If anyone in the business has built something with an AI API, spend 30 minutes finding out what it runs on.
List every AI integration
Ask staff and freelancers which chatbots, automations, Zapier or Make steps, plugins and scripts call an AI model. Include website chat widgets.
Find the key and its account
For each one, find which provider and which account the API key belongs to. Keys in a personal account are a problem in themselves.
Check billing status
For Gemini, check the key's Cloud project has an active billing account. For Mistral, check the Admin panel's 'Anonymous improvement data' toggle is off. For OpenAI, check Settings, Data controls, Sharing is disabled for the project.
Check what data goes in
Look at a few real requests or logs. If they contain names, contact details, IDs, health or financial details, the tool must be on paid, no-training terms.
Write it down
Record the provider, account owner, plan, data types and data-use setting in your IT asset or vendor register.
Switching a prototype to paid, no-training terms
Moving to paid terms is usually cheap for small volumes. Our LLM API pricing comparison shows per-token prices; for a small chatbot the bill is often a few dollars a month. The switch itself is mostly account housekeeping.
Before the tool touches customer data
If you need contractual data-residency or enterprise terms, compare the direct APIs with cloud-hosted versions; our Azure OpenAI vs OpenAI API guide covers that choice. For staff using chat apps rather than APIs, see our AI training opt-out settings guide.
When a free tier is fine
Free tiers are useful for learning and testing with made-up or public data: drafting prompts, trying models, building a demo with sample questions, or summarising your own published web pages. The rule is simple: if you would be comfortable posting the input on your website, the free tier is fine. If not, use paid terms.
Keep test and production separate. Use one project or key for experiments with dummy data, and a different, paid one for anything real, so a test key never ends up in the live tool.
Do it yourself or get help?
If you built the tool yourself, the audit and the switch to a paid account take an afternoon with this guide. Get help when you don't know what your freelancer built, when keys live in someone else's account, or when the tool handles IDs, health or financial details.
Our Custom Tool or Dashboard work (from S$1,990, fixed price in writing) rebuilds AI prototypes on business-owned, paid API accounts with logging, budget limits and data-use settings documented.
Frequently asked questions
Google's Gemini API terms say that for unpaid services, including the free quota and AI Studio, Google uses your prompts and responses to provide, improve and develop its products and machine learning technologies, and human reviewers may read them. Google tells users not to submit sensitive, confidential or personal information to unpaid services. Paid use through a billed Cloud project is excluded.
Not by default. OpenAI says data sent to its API has not been used to train or improve its models since 1 March 2023 unless you explicitly opt in. The main opt-in is the data sharing setting, which some organisations can enable in exchange for complimentary daily tokens. Check Settings, Data controls, Sharing on your API organisation.
Anthropic's privacy centre says that by default it does not use inputs or outputs from its commercial products, including the Anthropic API and Claude for Work, to train its models. It may use data you explicitly submit as feedback, such as thumbs up or down reports. Consumer Claude plans have separate settings.
The PDPA doesn't ban it outright, but your business stays responsible for that personal data. You need a purpose customers were told about, reasonable security, and care with providers that may reuse or let humans review the data. Sending customer data to a tier that uses it for product improvement is hard to justify. Use paid, no-training terms.
Google's terms say Gemini API access is a paid service only when you call it through a Google Cloud project with an active billing account. Open the project behind the key in Google Cloud or AI Studio and check that billing is enabled. A key on a project without billing is on the unpaid terms.