The policy states that personal data collected through use of HubSpot products and services may be processed to train HubSpot's AI models and develop AI-related features and products.
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 a secondary processing purpose beyond product delivery: personal data from product and service usage may be applied to AI model training. The provision does not specify which categories of personal data are used for training, which AI models or features are involved, or whether this processing is limited to aggregated or anonymized data versus identified personal data.
Interpretive note: The provision does not specify which data categories, which AI models, or which legal basis applies to AI training use, creating ambiguity regarding scope and compliance posture.
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, personal data generated through use of HubSpot's products and services may be processed for AI model training purposes in addition to direct service delivery. The provision does not include an opt-out mechanism specific to AI training use.
Cross-platform context
See how other platforms handle AI Model Training Using Personal Data and similar clauses.
Compare across platforms →"When you use our products and services we may process personal data to develop, support, and improve HubSpot AI features and to train our AI models and similar products and services that rely on machine learning.Excerpt from HubSpot's Privacy Policy
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This provision authorizes a secondary processing purpose beyond product delivery: personal data from product and service usage may be applied to AI model training. The provision does not specify which categories of personal data are used for training, which AI models or features are involved, or whether this processing is limited to aggregated or anonymized data versus identified personal data.
Under this clause, personal data generated through use of HubSpot's products and services may be processed for AI model training purposes in addition to direct service delivery. The provision does not include an opt-out mechanism specific to AI training use.
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