The policy states that when HubSpot customers install the HubSpot Tracking Code on their own websites, HubSpot collects IP addresses and online identifiers from those website visitors and processes this data as a controller for HubSpot's own purposes, including improvement of its commercial dataset.
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 that HubSpot assumes an independent controller role over data collected from visitors to customer-operated websites via the tracking code, distinct from its processor role under customer instructions. This means visitors to third-party websites using HubSpot infrastructure may have their data processed by HubSpot for HubSpot's own commercial purposes without direct notice from 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 →Under this clause, individuals who visit a website operated by a HubSpot customer that has installed the HubSpot Tracking Code may have their IP addresses and online identifiers collected and processed by HubSpot as a controller for HubSpot's own product improvement and commercial dataset enrichment purposes, independent of the website operator's own privacy disclosures.
Cross-platform context
See how other platforms handle HubSpot Tracking Code Controller Processing and similar clauses.
Compare across platforms →"Our Customers may install the HubSpot Tracking Code on their website to collect information about website visitors. HubSpot uses information collected by the tracking code, such as IP addresses and online identifiers, to improve our products and services, including our commercial dataset. We store information about website visitors on our servers and process this data for our own purposes as a controller.Excerpt from HubSpot's Privacy Policy
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This provision establishes that HubSpot assumes an independent controller role over data collected from visitors to customer-operated websites via the tracking code, distinct from its processor role under customer instructions. This means visitors to third-party websites using HubSpot infrastructure may have their data processed by HubSpot for HubSpot's own commercial purposes without direct notice from HubSpot.
Under this clause, individuals who visit a website operated by a HubSpot customer that has installed the HubSpot Tracking Code may have their IP addresses and online identifiers collected and processed by HubSpot as a controller for HubSpot's own product improvement and commercial dataset enrichment purposes, independent of the website operator's own privacy disclosures.
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