42 Total
9 High severity
13 Medium severity
20 Low severity

Key Facts

By agreeing to the DPA, does the customer consent to all listed affiliate sub-processors having access to Customer Data?
HubSpot requires that, by agreeing to the DPA, the customer consents to all listed affiliate sub-processors having access to Customer Data.
By agreeing to the DPA, does the customer consent to all listed infrastructure sub-processors having access to Customer Data?
HubSpot requires that, by agreeing to the DPA, the customer consents to all listed infrastructure sub-processors having access to Customer Data.
Does HubSpot incorporate the Sub-Processors Page into the DPA and Agreement?
HubSpot incorporates the Sub-Processors Page into the DPA and Agreement.
Does HubSpot distinguish between sub-processors that apply by default and sub-processors that apply only if and when the customer opts in?
HubSpot distinguishes between sub-processors that apply by default and sub-processors that apply only if and when the customer opts in.
May HubSpot deprecate a sub-processor?
HubSpot may deprecate a sub-processor to consolidate and minimize its use of sub-processors, or may add a sub-processor if HubSpot believes doing so will enhance its ability to deliver the Subscription Service.
May HubSpot add a sub-processor?
HubSpot may deprecate a sub-processor to consolidate and minimize its use of sub-processors, or may add a sub-processor if HubSpot believes doing so will enhance its ability to deliver the Subscription Service.
Why may HubSpot deprecate or add a sub-processor?
HubSpot may deprecate a sub-processor to consolidate and minimize its use of sub-processors, or may add a sub-processor if HubSpot believes doing so will enhance its ability to deliver the Subscription Service.
Does HubSpot use OpenAI, L.L.C. as an AI service provider for HubSpot AI?
HubSpot uses OpenAI, L.L.C. as an AI service provider for HubSpot AI, with processing covering the United States, European Economic Area, and Switzerland.
Does HubSpot notify customers before they turn on a feature or install an integration that requires support from an opt-in sub-processor?
HubSpot will notify customers before they turn on a feature or install an integration that requires support from an opt-in sub-processor.
Does HubSpot allow customers to subscribe to receive email notifications?
HubSpot allows customers to subscribe to receive email notifications if HubSpot updates the sub-processors page to add or replace sub-processors, if any sub-processor materially changes the services they provide, or if a sub-processor changes the country from which it provides services.
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Summary

This document lists the third-party companies HubSpot shares your data with and explains how that sharing is authorized. When you agree to HubSpot's DPA, you automatically consent to all listed sub-processors accessing your data—some are active by default, while others only apply if you turn on specific features. HubSpot can add or remove sub-processors at its discretion, but if you subscribe to email notifications, it must give you at least 30 days' notice before any change takes effect.

Analysis

This document establishes HubSpot's sub-processor framework as incorporated into the DPA and Agreement, giving it binding contractual force. Customers consent to both affiliate and infrastructure sub-processor access to Customer Data through their agreement to the DPA, without a separate opt-in at the point of sub-processor engagement. HubSpot distinguishes between default sub-processors—active without affirmative customer action—and opt-in sub-processors, which require deliberate customer activation preceded by pre-activation notice. HubSpot retains discretion to add or deprecate sub-processors based on its own assessment of service enhancement or consolidation goals, subject to a 30-day advance notice obligation for customers who subscribe to email notifications.

What this means for you

By agreeing to HubSpot's DPA, a user consents in advance to all listed affiliate and infrastructure sub-processors accessing their Customer Data—including providers such as AWS, Cloudflare, and OpenAI for HubSpot AI features—without requiring a separate approval at the time each sub-processor is engaged. Some sub-processors are active by default, while others only become active when a user turns on a specific feature or integration; HubSpot will notify the user before they activate any feature that requires an opt-in sub-processor. To receive at least 30 days' advance notice before any sub-processor is added, replaced, or materially changed, a user can subscribe to HubSpot's email notification service for sub-processor updates.

Institutional Analysis
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Institutional analysis available with Insight

Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.

Featured, High severity
Featured, Medium severity

Complete Provision Index

Every distinct legal provision identified in this document. Featured provisions appear above with analysis.

42 provisions
12 featured
8 clause types
9 high severity
Data Sharing 31 2 high
Show all 31 data sharing provisions
AI / Automated Decision-Making 2 1 high
General Contract Terms 1 1 high
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Mapped Governance Frameworks

CCPA/CPRA
California, USA
View official text ↗
Connecticut Data Privacy Act Amendments
US-CT
View official text ↗
CAN-SPAM
United States Federal
View official text ↗
FTC Act Section 5
United States Federal
View official text ↗
GDPR
European Union
View official text ↗
Indiana Consumer Data Protection Act
US-IN
View official text ↗
Kentucky Consumer Data Protection Act
US-KY
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗
VPPA
United States Federal
View official text ↗
Archival ProvenanceSource & Archival Record
Last Captured July 6, 2026 22:44 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000932
Version ID CA-V-004530
SHA-256 be1ee395d61eaf157e884c8abd16fb6f7764b8b8dffdb3704efbafbd67a0364d
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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