In almost every case, yes, at least momentarily — and that’s a separate question from whether the vendor trains on it or how long it keeps it.
Short answer
In almost every case, yes. Running your input through an AI product means the vendor's own infrastructure processes it to generate a response, and many vendors log that traffic for abuse monitoring, debugging or legal-compliance purposes even when a “don't train on my data” setting is switched on — a training opt-out and an access opt-out are not the same control. What Canadian privacy law actually requires doesn't depend on which vendor claims which practice; it requires your business to remain accountable for the information regardless.
It's worth separating these before trusting any one vendor claim. Whether the company behind the tool (its systems, its staff) can access what you typed is this question. Whether that input is later used to train a model is a different, narrower question — see whether you can stop a tool training on your data. How long the input sits on the vendor's servers either way is a third question — see how long an AI tool keeps your prompts. A vendor can truthfully say it doesn't train on your data while its support and security teams still have routine access to it.
PIPEDA Schedule 1, clause 4.1.3 is the operative anchor: “An organization is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. The organization shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.” Sending information into an AI vendor's product is a transfer for processing, and accountability for it does not move to the vendor just because the vendor's system is the one holding it at any given moment.
Canada's joint federal-provincial-territorial generative-AI principles push this further before the data ever leaves your hands: organizations should “consider whether the use of a generative AI system is necessary and proportionate… the tool should be more than simply potentially useful. This consideration should be evidence-based and establish that the tool is both necessary and likely to be effective in achieving the specified purpose.” In practice, that means the question isn't only what the vendor can see — it's whether sending that particular information to that particular tool was justified in the first place.
The setting that actually matters is buried in the specific plan or tier you're on, not the vendor's general privacy marketing. Free consumer tiers commonly reserve broader rights over inputs than paid enterprise or API tiers with contractual no-training and limited-access terms — see when an AI tool counts as a straightforward service provider for how that distinction is actually drawn. Treadstone Law’s answer on sharing customer data with a third-party provider covers the underlying consent-and-contract question for any vendor, AI or not.
See how a live AI system gets kept accountable once it's running.
