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
Personal Data in HubSpot's commercial dataset is not held exclusively by HubSpot; it may be passed to third-party customers for their own use.
Interpretive note: The second independent proposition—that customers may use the shared data for sales, marketing, and other business activities—was omitted from the canonical claim and recorded in omitted_material.
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 →Your Personal Data held in HubSpot's commercial dataset may be shared with HubSpot customers, who may then use it for sales, marketing, and other business activities.
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"We may share Personal Data about individuals in our commercial dataset with our customers that use our enrichment features. Customers may use this information for their sales, marketing and other business activities.Excerpt from HubSpot's Privacy Policy
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Personal Data in HubSpot's commercial dataset is not held exclusively by HubSpot; it may be passed to third-party customers for their own use.
Your Personal Data held in HubSpot's commercial dataset may be shared with HubSpot customers, who may then use it for sales, marketing, and other business activities.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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