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
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.
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 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
See how other platforms handle Legitimate Interests Basis for Marketing and Professional Data Processing and similar clauses.
Compare across platforms →"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
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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.
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.
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