HubSpot · HubSpot Privacy Policy · View original document ↗

Dual Controller/Processor Role

Medium severity Rare · 1 of 325 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The dual-role structure defines HubSpot's legal responsibilities and regulatory obligations under data protection frameworks. When operating as a controller, HubSpot bears primary responsibility for processing decisions; when operating as a processor, responsibility for lawfulness and data subject rights transfers to the customer as controller, while HubSpot assumes data handling obligations specified in processing agreements.

Consumer impact (what this means for users)

For individuals whose data HubSpot collects directly (website visitors), HubSpot functions as the accountable party for processing decisions and privacy obligations. For individuals whose data customers upload to HubSpot Services, the customer assumes controller responsibility while HubSpot operates under the customer's processing instructions, meaning data subject requests and compliance obligations flow through the customer rather than directly to HubSpot.

How other platforms handle this

Amplitude Medium

Amplitude acts as a data controller when we collect and use Personal Information for our own purposes, such as providing and improving our Services, marketing, and other business operations. When Amplitude processes Personal Information on behalf of our customers (for example, event data that our cu...

DocuSign Medium

When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For certain products such as Docusign's Contract Lifecycle Management (CLM) and Identity products, we may act as a processor and as a controller in certa...

TikTok Medium

To make the Platform more relevant and enjoyable for you, we customize parts of your experience on the Platform to show you creators and content we think you will be interested in, including ads and other content sponsored by or in collaboration with our creators and our partners. We customize what ...

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▸ View Original Clause Language DOCUMENT RECORD
"
HubSpot acts as a data controller when we collect and process personal information about visitors to our Websites and for our own business purposes. HubSpot acts as a data processor when we process personal information on behalf of our customers using our Services. In those cases, our customers are the data controllers and are responsible for the personal information they upload to our Services.

— Excerpt from HubSpot's HubSpot Privacy Policy

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
HubSpot Privacy Policy
Entity
HubSpot
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-006510
Document ID
CA-D-00208
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fe8174733afb623b01d20e9bf2797cfe1a6f367f639df8ac00b981f71a13d9ef
Analysis generated
May 10, 2026 22:52 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: HubSpot
Document: HubSpot Privacy Policy
Record ID: CA-P-006510
Captured: 2026-05-10 22:52:49 UTC
SHA-256: fe8174733afb623b…
URL: https://conductatlas.com/platform/hubspot/hubspot-privacy-policy/dual-controllerprocessor-role/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does HubSpot's Dual Controller/Processor Role clause do?

The dual-role structure defines HubSpot's legal responsibilities and regulatory obligations under data protection frameworks. When operating as a controller, HubSpot bears primary responsibility for processing decisions; when operating as a processor, responsibility for lawfulness and data subject rights transfers to the customer as controller, while HubSpot assumes data handling obligations specified in processing agreements.

How does this clause affect you?

For individuals whose data HubSpot collects directly (website visitors), HubSpot functions as the accountable party for processing decisions and privacy obligations. For individuals whose data customers upload to HubSpot Services, the customer assumes controller responsibility while HubSpot operates under the customer's processing instructions, meaning data subject requests and compliance obligations flow through the customer rather than directly to HubSpot.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with HubSpot?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by HubSpot.