Provision record
HubSpot · HubSpot Privacy Policy · View original document ↗

Legitimate Interests Basis for Marketing and Professional Data Processing

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Document Record

What it is

The policy states that where applicable law does not require consent, HubSpot conducts marketing and advertising activities on the basis of legitimate business interests, and may combine data from third-party providers with other collected information for personalized communications and event promotion.

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)

This provision establishes legitimate interests as the default legal basis for marketing activities targeting individuals who have not provided explicit consent, and authorizes combination of third-party sourced data with HubSpot-collected data for personalized outreach. The provision is conditioned on legal requirements in applicable jurisdictions, acknowledging that consent will be obtained where law requires it.

Interpretive note: The policy does not describe the documented balancing test supporting legitimate interests for marketing, and the scope of 'where required by law' consent conditions varies by jurisdiction.

Recent Activity

This document changed recently

Medium Jul 2, 2026

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, individuals who have not opted out of marketing may receive personalized communications based on combined data from HubSpot and third-party sources, unless they are in a jurisdiction where opt-in consent is required. Marketing opt-out is available by following the unsubscribe instructions in each HubSpot communication.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests. We may use information collected from third party service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and improved services, personalized communications, event promotion, and to otherwise improve the user experience.

Excerpt from HubSpot's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
HubSpot Privacy Policy
Entity
HubSpot
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015854
Document ID
CA-D-00208
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8bdd9c02627e237bfc8804ce37c491bfe0d5ec7f6135c78f3b37490f6c0f7ed9
Analysis generated
July 9, 2026 08:57 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: HubSpot
Document: HubSpot Privacy Policy
Record ID: CA-P-015854
Captured: 2026-07-09 08:57:39 UTC
SHA-256: 8bdd9c02627e237b…
URL: https://conductatlas.com/platform/hubspot/hubspot-privacy-policy/provision/CA-P-015854/legitimate-interests-basis-for-marketing-and-professional-data-processing/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

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Frequently Asked Questions

What does HubSpot's Legitimate Interests Basis for Marketing and Professional Data Processing clause do?

This provision establishes legitimate interests as the default legal basis for marketing activities targeting individuals who have not provided explicit consent, and authorizes combination of third-party sourced data with HubSpot-collected data for personalized outreach. The provision is conditioned on legal requirements in applicable jurisdictions, acknowledging that consent will be obtained where law requires it.

How does this clause affect you?

Under this clause, individuals who have not opted out of marketing may receive personalized communications based on combined data from HubSpot and third-party sources, unless they are in a jurisdiction where opt-in consent is required. Marketing opt-out is available by following the unsubscribe instructions in each HubSpot communication.

Is ConductAtlas affiliated with HubSpot?

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