Data Sharing with Third-Party Service Providers and Partners

What it is

HubSpot shares your personal data with vendors, advertising companies, and other partners who help operate its services, subject to contractual requirements that they protect the data.

Why it matters (compliance & governance perspective)

Sharing personal data with advertising partners in particular expands the number of organizations that may have access to your information, which increases privacy risk and may involve cross-context behavioral advertising.

Consumer impact (what this means for users)

Your personal data may be shared with a range of third-party vendors and advertising partners, meaning entities beyond HubSpot may store and use your information. HubSpot states it requires these parties to protect your data, but the practical enforcement of those contractual requirements is not independently verifiable by individual consumers.

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision engages GDPR Article 28 (processor contracts) and Article 6 (lawfulness of sharing), enforced by EU supervisory authorities. Under CCPA/CPRA, sharing personal data with advertising partners for cross-context behavioral advertising is a regulated activity subject to opt-out rights, enforced by the California Privacy Protection Agency. The FTC Act Section 5 applies to deceptive representations about third-party data sharing practices. GOVERNANCE EXPOSURE: Medium. The breadth of third-party sharing, particularly with advertising partners, is standard for SaaS marketing platforms but requires robust sub-processor management and disclosure. HubSpot's statement that it requires third parties to comply with the law is a standard contractual representation but does not independently verify the adequacy of third-party practices. JURISDICTION FLAGS: EU/EEA requires that all sub-processors be subject to data protection obligations equivalent to the main DPA, and sub-processor changes must be notified to business customers. California requires disclosure of categories of third parties with whom personal data is shared. Jurisdictions with comprehensive privacy laws increasingly require controller accountability for downstream processor practices. CONTRACT AND VENDOR IMPLICATIONS: Business customers should review HubSpot's sub-processor list and ensure they have approved or can object to sub-processor additions as required by their DPA. The policy's general statement about third-party contractual requirements should be verified against actual DPA terms, which may contain more specific obligations and audit rights. COMPLIANCE CONSIDERATIONS: Compliance teams should request HubSpot's current sub-processor list and establish a process for monitoring sub-processor changes. Privacy impact assessments may be warranted for high-risk sub-processors, particularly those involved in advertising technology. Business customers should confirm that their own privacy notices disclose HubSpot's sub-processors to the extent required by applicable law.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Dual Controller/Processor Framework high
• International Data Transfers via Standard Contractual Clauses medium
• Cookies and Advertising Tracking medium
• Data Subject Rights Request Process medium
• Legitimate Interests as a Legal Basis for Processing medium
• CCPA California Resident Rights and Data Sale Opt-Out medium

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