When a business uses HubSpot's tools to manage contacts or run marketing campaigns, HubSpot is acting on that business's instructions, not as an independent decision-maker over your data. This means if you want to access or delete data a business holds about you in HubSpot, you need to contact that business, not HubSpot.
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 determines who is responsible for your data and who you can hold accountable. If a company stored your email address in HubSpot without your knowledge, your legal rights run against that company, not HubSpot.
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 →Simplified and clarified the controller-processor relationship, removing references to 'Customer Data' and 'Contacts' terminology in favor of more standardized 'personal data' language, and emphasized regulatory compliance responsibility.
View full change record →If your personal data (such as your email address, name, or purchase history) is held in a business's HubSpot CRM, your right to access, correct, or delete that data must be exercised with the business, not HubSpot. HubSpot's role in that context is limited to following the business's instructions.
How other platforms handle this
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.
to object to profiling activities based on our own legitimate interests
"In providing the Products, HubSpot may process personal data on behalf of Customers. In this context, we are a data processor and the Customer is the data controller. The Customer is responsible for complying with any regulations or laws that require providing notice, disclosure, or obtaining consent prior to using HubSpot to collect this data. We process the data in accordance with our agreements with our Customers.Excerpt from HubSpot's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages GDPR Articles 4(7) and 4(8) on controller and processor definitions, and Article 28 on processor obligations, enforced by EU data protection authorities including the Irish DPC as HubSpot's lead …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision determines who is responsible for your data and who you can hold accountable. If a company stored your email address in HubSpot without your knowledge, your legal rights run against that company, not HubSpot.
If your personal data (such as your email address, name, or purchase history) is held in a business's HubSpot CRM, your right to access, correct, or delete that data must be exercised with the business, not HubSpot. HubSpot's role in that context is limited to following the business's instructions.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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