41 Total

Key Facts · in the document’s own words

By agreeing to the DPA, does the customer consent to all listed affiliate sub-processors having access to Customer Data?
“By agreeing to the DPA, you agree all of these Sub-Processors may have access to Customer Data.”
Version CA-V-006999, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“By agreeing to the DPA, you agree all of these Sub-Processors may have access to Customer Data.”
Version CA-V-006999, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“This HubSpot Sub-Processors Page is incorporated into the DPA and Agreement.”
Version CA-V-006999, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“Some Sub-Processors will apply to you as a default, and some Sub-Processors will apply to you only if and when you opt-in.”
Version CA-V-006999, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“We may deprecate a Sub-Processor to consolidate and minimize our use of Sub-Processors, or we may add a Sub-Processor if we believe that doing so will enhance our ability to deliver our Subscription Service.”
Version CA-V-006999, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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?
“OpenAI, L.L.C. AI Service Provider HubSpot AI United States European Economic Area and Switzerland United States United States”
Version CA-V-006999, captured Sept. 17, 2026 · live source ↗
Our reading, not the document’s words
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.
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Summary
Generated by a model from the captured document; not read by a person

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

Clauses withheld

We withheld clauses we had published from this document. Each withholding is recorded in our correction log:

Featured provisions
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Complete Provision Index

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

41 provisions
12 featured
7 clause types
Data Sharing 31
Show all 31 data sharing provisions
General Contract Terms 1
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Archival ProvenanceSource & Archival Record
This version captured September 17, 2026 00:32 UTC
Last successful capture October 15, 2026 00:28 UTC
Date stated by the document September 16, 2026 (as printed in this version)
Capture Method Automated scheduled archival capture
Document ID CA-D-000932
Version ID CA-V-006999
SHA-256 (extracted text, extractor v5) 426bcf380155ff8b05ca72e956867a53285b23da950773c56ca4331a6fd27082
Archived bytes SHA-256 (anchor) 2b026be68c3e9e6e86cb8bc706797a89f1fce413ee599ae83294b2113f53d6fc
✓ Snapshot stored ✓ Archived bytes anchored (verified Sept. 17, 2026)

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