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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
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.
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We will disclose information to third parties about your account or the transfers you make: (i) where it is necessary for completing transfers, or (ii) in order to verify the existence and condition of your account...
We may also use IP address or other device identifiers to identify individuals, either acting alone or in cooperation with third parties such as copyright owners, internet service providers...
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"When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses...Excerpt from HubSpot's Privacy Policy
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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
The clause states: “When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses...”
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
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