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The policy states that HubSpot shares personal data including email addresses with advertising partners to enable delivery of personalized HubSpot advertisements on third-party websites and mobile applications, and that users can opt out via a form linked in the policy.
This analysis describes what HubSpot's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision authorizes disclosure of email addresses to third-party advertising networks for cross-site ad targeting. An opt-out mechanism is described, but the default position is that email addresses are shared with advertising partners unless users affirmatively opt out.
The updated policy now explicitly discloses that HubSpot collects Email Engagement Data (such as open, delivery, bounce, and click statuses) from emails sent through its Subscription Services using embedded tracking technologies. This represents formalization of a data collection practice into explicit policy language. However, the policy simultaneously removed a previously stated sentence directing users to a form for removing their personal data from HubSpot's commercial dataset. The updated terms do not indicate an alternative removal mechanism.
View change record →Under this clause, email addresses provided to HubSpot may be shared with advertising partners by default, enabling HubSpot-branded advertising to follow users across third-party websites and apps. Users can opt out of this disclosure by submitting the form referenced in Section 3.5 of the policy.
Cross-platform context
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"We allow advertising networks to collect information about your interactions with our websites in order to deliver HubSpot's personalized ads. We may also share Personal Data, such as your email address, with our advertising partners to deliver HubSpot's personalized ads on other companies' sites or mobile apps. You can opt out of having your data disclosed to our advertising partners through this form.Excerpt from HubSpot's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages GDPR Articles 6 and 7 regarding consent for email-based ad targeting, CCPA provisions regarding sale or sharing of personal information (email addresses shared with advertising networks for cross-context behavioral advertising may constitute sharing under CCPA), and the FTC Act Section 5 regarding unfair or deceptive advertising data practices. The ePrivacy Directive may also apply to email-based targeting of EEA users. 2. GOVERNANCE EXPOSURE: Medium. The opt-out default for advertising partner email sharing may conflict with GDPR consent requirements for EEA users, where opt-in consent is generally required for behavioral advertising. The policy states that where required by law, marketing will only be sent with consent, but does not specify whether this consent standard applies to advertising partner disclosure specifically. 3. JURISDICTION FLAGS: EEA and UK users face heightened exposure as GDPR generally requires opt-in consent for behavioral advertising data sharing. California residents have CCPA rights to opt out of sharing of personal information for cross-context behavioral advertising. Canada's PIPEDA requires opt-in consent for disclosure of personal information to third parties for marketing. 4. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should assess whether advertising partner data sharing agreements include data processing addenda that comply with GDPR and CCPA requirements, and whether advertising partners are included in HubSpot's data processing agreements. 5. COMPLIANCE CONSIDERATIONS: Legal teams should verify whether the opt-out mechanism described is technically implemented and whether email addresses shared with advertising partners prior to an opt-out request are deleted from partner systems. For EEA and UK users, consent records should be audited to confirm that advertising partner disclosure is based on affirmative consent rather than legitimate interests.
This provision authorizes disclosure of email addresses to third-party advertising networks for cross-site ad targeting. An opt-out mechanism is described, but the default position is that email addresses are shared with advertising partners unless users affirmatively opt out.
Under this clause, email addresses provided to HubSpot may be shared with advertising partners by default, enabling HubSpot-branded advertising to follow users across third-party websites and apps. Users can opt out of this disclosure by submitting the form referenced in Section 3.5 of the policy.
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