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

Enrichment Product Commercial Dataset

High severity High confidence Explicit document language Unique · 0 of 352 platforms
Stay ahead of the changes
Track HubSpot and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

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, 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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Navigate to the opt-out and deletion form linked in Section 1.5 and Section 7 of the HubSpot Privacy Policy and submit a request to remove your personal data from the commercial enrichment dataset.

Cross-platform context

See how other platforms handle Enrichment Product Commercial Dataset and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

Unlock the full institutional analysis

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 →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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-015849
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-015849
Captured: 2026-07-09 08:57:39 UTC
SHA-256: 8bdd9c02627e237b…
URL: https://conductatlas.com/platform/hubspot/hubspot-privacy-policy/provision/CA-P-015849/enrichment-product-commercial-dataset/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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.

Frequently Asked Questions

What does HubSpot's Enrichment Product Commercial Dataset clause do?

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.

How does this clause affect you?

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 …

Is ConductAtlas affiliated with HubSpot?

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