The policy states that HubSpot collects professional personal data including business contact information from public sources, third-party providers, and its own customers, and distributes this data to other HubSpot customers for sales and marketing use through enrichment product features.
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 establishes HubSpot's role as a controller of a commercial dataset of professional personal data that is collected from individuals who are not direct HubSpot users and made available to paying customers. The policy relies on legitimate interests as the legal basis for this processing, asserting that people would expect their work-related data to be shared in this way.
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 including email addresses, phone numbers, job titles, and physical addresses sourced from public records, third parties, and HubSpot customers may be included in a commercial dataset and distributed to HubSpot customers for sales and marketing outreach without direct notice to the individual. Individuals can request removal from the commercial dataset by submitting the opt-out form linked in the policy.
Cross-platform context
See how other platforms handle Enrichment Product Commercial Dataset and similar clauses.
Compare across platforms →"HubSpot collects business contact and similar professional data from various sources, including publicly available sources, third party providers, and customers who use our enrichment products. This information powers our commercial dataset. We provide information from our commercial dataset to customers who choose to use enrichment products within the Subscription Services as part of their sales, marketing, and other business activities. If you'd like to remove your Personal Data from our commercial dataset, complete and submit this form.Excerpt from HubSpot's Privacy Policy
1.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Search "[your state] attorney general consumer complaint" to find your state's direct complaint form
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision establishes HubSpot's role as a controller of a commercial dataset of professional personal data that is collected from individuals who are not direct HubSpot users and made available to paying customers. The policy relies on legitimate interests as the legal basis for this processing, asserting that people would expect their work-related data to be shared in this way.
Under this clause, personal data including email addresses, phone numbers, job titles, and physical addresses sourced from public records, third parties, and HubSpot customers may be included in a commercial dataset and distributed to HubSpot customers for sales and marketing outreach without direct notice to the individual. Individuals can request removal from the commercial dataset by submitting the opt-out form …
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by HubSpot.