Selling Data From a Shut-Down or Defunct Company to AI Labs

A shut-down or defunct company can license or sell its code, chats, email and documents to AI labs only through whoever still holds authority over its assets, and only within the privacy, employee and contract duties that survive the closure. Named programs state that they accept closed companies, and each term is a dated claim: micro1 states a defunct track with company compensation of USD 100,000 to 3,000,000 or more, and Turing states a revenue share with nothing upfront (both checked 2026-11-09).

Deleting the archive once retention periods end is an equally valid outcome. A closed company's archive is one source in AI training data licensing.

DataPacts Editorial Team checked every figure here against its primary source on November 9, 2026; the page on how we source, date and check every figure sets out the rules.

What a Closed Company's Data Sale Covers and What Labs Want

When a startup shuts down, its records of how work was done, mainly code, chat, email and documents, are the asset AI labs and data vendors license, while the brand and customer lists are a separate sale. SimpleClosure states that its AssetHub workspaces use Slack in 95 %, Google Drive in 87 % and GitHub in 82 % of cases, and that cleaning removes roughly 37 % of raw code (blog post of 2026-09-03). The sources fall into four groups:

• source code and commit history
• chat and email
• documents and wikis
• tickets and CRM records

The one seller-stated amount in the record is a founder's statement to MIT Technology Review on 2026-10-13 that a code-base sale netted roughly USD 25,000.

Who Can Sign the License After the Company Closes

The party that can grant a license changes as a company moves from operating to winding up to dissolved, and a license signed by someone without authority conveys nothing.

Before Dissolution: The Company Acting Through Its Officers

Until dissolution, the company itself licenses its data, acting through its board or directors, and a sale of substantially all its assets can also need shareholder approval. Under 8 Del. C. 271(a), a Delaware corporation needs a majority of the outstanding voting stock, voted at a meeting held on at least 20 days' notice, to sell all or substantially all of its assets.

Ooak Data states that its wind-down deals close with a director, liquidator or administrator signing (checked 2026-11-09).

After Dissolution: Winding-Up Parties, the Crown and Restoration

After dissolution, authority depends on the jurisdiction: a Delaware corporation continues for winding up, while a UK company's remaining property passes to the Crown. Under 8 Del. C. 278 a dissolved Delaware corporation continues for three years, or longer as the Court of Chancery directs, and under section 279 the Court may appoint trustees or receivers.

In the United Kingdom, section 1012 of the Companies Act 2006 makes the property of a dissolved company bona vacantia, the directors lose authority to sell it, and restoration is possible within six years (sections 1024 and 1030). The Bona Vacantia Division's guidance BVC1 (2022-09-28) states that "Normally an asset will either be disclaimed or sold for full market value." Ownership of the data itself is covered under who owns a dissolved company's data.

Assignees, Successors and Acquirers

An assignee for the benefit of creditors, a merger successor or an acquirer can license the data only to the extent the transfer gave it the data and the rights attached to it. In Delaware, 10 Del. C. ch. 73A governs assignments and the assignee petitions the Court of Chancery within 14 days; the former sections 7381 to 7387 were repealed effective 2026-06-10. An assignment has no consumer privacy ombudsman mechanism.

No general rule on a successor's right to license a target's data is stated here: the purchase agreement decides, as set out under data from acquired companies.

Duties to Customers, Staff and Vendors That Outlive the Company

Closing a company does not end the privacy promises it made, the employment and confidentiality terms it signed, or the platform terms its data sits under.

Customers and Users: Privacy Promises and Purpose Limits

A company's privacy policy and customer contracts still define what may be done with customer and user data after closure, and training a model is usually a new purpose. FTC staff stated on 2024-02-13 that retroactive, surreptitious changes to terms to allow AI training "may be unfair or deceptive"; the statement is a staff blog post, not a rule. In a US bankruptcy, 11 U.S.C. 363(b)(1) and 332 apply to personal information covered by a privacy policy.

Regulation (EU) 2016/679, applicable since 2018-05-25, tests further use under Article 6(4) by its compatibility factors. For EU customers, the rules on GDPR and AI training data also require under Article 13(3) that data subjects are informed before processing for another purpose.

Former Employees' Mailboxes, Chats and HR Records

Workspace archives hold former employees' personal data, and data-protection law keeps applying to a company in liquidation, as an Italian decision of April 2026 shows. On 2026-04-17 the Garante (registro n. 278) fined Framos Italia s.r.l. in liquidazione EUR 5,000 for keeping two mailboxes of a former employee active from 2023-06-30 to 2023-12-21, taking the liquidation into account. The decision concerns mailbox retention, not an AI sale.

An attorney quoted by MIT Technology Review on 2026-10-13 called employee data sales "legally radioactive".

SimpleClosure states that it excludes sensitive employee, compensation, health and personal information, and AfterQuery states that payroll, privileged legal material and credentials are never used (checked 2026-11-09). Staff notice and consent are covered under employee notice and consent.

Account Deletion Clocks at Slack, Google, Microsoft and GitHub

Cancelling workspace subscriptions starts deletion clocks, so a closing company that may license its data decides before it cancels. The table compares what each system does after closure or cancellation, as of 2026-11-09.

Each clock is a fact about the vendor, not a reason to sell. The export process is covered under vendor deletion deadlines.

Buyer Programs and Intermediaries With Terms for Closed Companies

Several company-data programs state that they accept closed or winding-down companies, and several intermediaries place such data with buyers without licensing it themselves. The table compares them as of 2026-11-09, and every value is the party's own claim.

Referral fees (checked 2026-11-09): micro1 defunct track USD 75,000 up to USD 1 million, 7.5 % above, paid after transfer and approval; Replay the greater of USD 10,000 or 10 % of the upfront fee, paid the day that fee lands; Turing up to USD 50,000 if the record sells. DataPacts links no referral codes.

Programs That Accept Closed or Winding-Down Companies

Four programs name closed or winding-down companies on their own pages, each with different payment terms, checked November 9, 2026. Replay, which states no closed-company wording, is described below.

micro1 states that it de-identifies and transforms sensitive information itself. Its Data License Master Terms (updated 2026-11-08) take a nonexclusive, irrevocable, perpetual grant, delete raw data at the earlier of 120 days after delivery or termination, and impose no duty to delete or retrain models (section 4.4).

Turing states that Project Lazarus accepts active, winding-down and wound-down companies, pays a revenue share with nothing upfront, licenses non-exclusively as sole seller for the first 90 days, and covers de-identification itself. AfterQuery gives no payout figures. The full list of company data partnership programs covers operating and closed companies.

Wind-Down Services and Referral Pages Are Not Buyers

Wind-down services and referral pages connect a closing company with buyers, take a fee or commission, and are not the licensee. SimpleClosure states no upfront cost, a percentage only if an asset is sold or licensed, and deal sizes of tens to hundreds of thousands of dollars for unique assets (checked 2026-11-09).

Sunset is a wind-down service for venture-backed startups, and Replay's About page says Replay's founder started it. Replay licenses de-identified company data to frontier AI and data labs (checked 2026-11-09). Replay's terms name Replay Data, LLC while its footer names Sunsets HQ Corp.; both names are shown as found.

The Corner is an independent referral partner of micro1, not micro1, and states that it takes closed companies with 25+ staff at peak. Referral timing differs: micro1 pays after the data is transferred and approved, Replay on the day the upfront fee lands and Turing if the referred record sells. Such services are compared under shutdown services for closing companies.

Benefits, Risks and Downsides of a Closed-Company Data Sale, and the Options Besides It

Licensing a closed company's data can return money to creditors and shareholders, but it carries privacy, employee and reputational risk that outlasts the company, and not selling is a valid outcome.

Benefits

• Money for an asset that would otherwise be deleted.
• Income after closure where a program pays a revenue share, as Replay and Turing state (checked 2026-11-09).

Risks

• Employee data, as the Garante fine of 2026-04-17 shows.
• Retroactive terms, as the FTC staff view of 2024-02-13 describes.
• A perpetual license with no duty to retrain, as in micro1's terms.
• A license signed without authority conveys nothing.

Downsides

• Cleaning removes part of the archive: roughly 37 % of raw code, SimpleClosure states.
• Nothing upfront under a revenue share, as Turing states.
• No seller-confirmed totals exist beyond one founder's statement.

Alternatives

• Delete the archive once retention periods end, for example 10 years for German books and annual accounts (HGB 257(4)) and 3 years for UK private company accounting records (Companies Act 2006 s.388(4)).
• License only the code and exclude workspace data.
• Not selling at all.

No option is the default, and each leaves the company's duties in place. Further options are compared under alternatives to selling data to AI labs.

Steps From the Closure Decision to a Signed License

A closed company reaches a signed license in six steps, and the first two decide whether the rest is possible.

1. Confirm who can sign for the company at its current stage.
2. List the vendor deletion clocks that apply before any subscription is cancelled.
3. List the systems and the exclusions, such as payroll, privileged material and credentials.
4. Check customer, employee and vendor terms.
5. Collect written offers from more than one program or intermediary and compare license grant, deletion and payment trigger.
6. Sign, then supervise de-identification and delivery.

Where a Closed-Company Sale Meets Insolvency and the Seller Process

When a closing company cannot pay its debts, the sale moves into an insolvency procedure, and an administrator, liquidator or trustee, not the founders, decides and usually needs court or creditor approval. In the Spirit Airlines case (Bankr. S.D.N.Y. 25-11897, Dkt. 1463, 2026-08-14), Google LLC's successful bid is USD 10,000,000 and Mercor.io Corporation's alternate bid USD 7,500,000; the sale is not approved as of 2026-11-09, with a hearing set for 2026-11-17 (Dkt. 1779). Officeholder sales of data assets in insolvency are covered separately.

A closed company is one entry among every type of seller, and the guide on how to sell or license company data to AI companies covers the full process. The linked pages cover these steps:

• rights audit: whether the company owns what it would license
• PII removal and de-identification
• board and shareholder approval
• AI data licensing agreements: license grant, deletion and payment clauses
• record retention after closing a company

This page is information, not legal advice.

Program and Intermediary Profiles Named on This Page

The terms above come from these programs' and intermediaries' own pages, checked November 9, 2026.

• AfterQuery
• micro1 data buyer profile
• Ooak Data
• Replay
• SimpleClosure
• Sunset
• The Corner
• Turing Project Lazarus

Terms side by side are on AI data partnership payouts and program terms compared, and who buys AI training data covers every buyer.

Frequently Asked Questions

Who buys data from closed companies?

Company-data programs run by data vendors and human-data companies license closed companies' archives, often through wind-down services that act as intermediaries. micro1, Turing, AfterQuery and Ooak Data state terms for closed companies, and Replay states terms for companies in any industry (checked 2026-11-09).

How much is a shut-down startup's data worth?

No public rate exists; the figures in the record are programs' and intermediaries' claims plus one founder's statement of about USD 25,000 net for a code base (MIT Technology Review, 2026-10-13). SimpleClosure states tens to hundreds of thousands of dollars for unique assets (checked 2026-11-09). Methods are covered under what company data is worth to AI companies.

Does a referral fee reduce what the company receives?

Only Replay, among the programs here, states that its referral fee does not reduce the company's payment, and each program pays only after a stated event. Replay states its fee is paid "on top of the company's payment" (checked 2026-11-09). Advisers can compare referral programs of AI data buyers.