Provision record
HubSpot · HubSpot Sub-Processors · View original document ↗

Advance DPA Consent to Infrastructure and Affiliate Sub-Processors

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Document Record

What it is

This provision states that a customer's agreement to HubSpot's DPA constitutes advance consent to all listed infrastructure Sub-Processors (Amazon Web Services, Cloudflare, Google LLC, Snowflake) and all fifteen HubSpot affiliate entities having access to Customer Data.

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 a general authorization mechanism for sub-processor data access, meaning customers do not provide separate, per-Sub-Processor approval at the time each Sub-Processor is engaged. Under GDPR Article 28(2), general written authorization for sub-processors is permitted, but the controller must be informed of intended sub-processor changes and retain the ability to object; whether HubSpot's DPA implements that objection right is not addressed in this document.

Consumer impact (what this means for users)

This provision establishes that agreeing to HubSpot's DPA constitutes advance consent to infrastructure Sub-Processors and all fifteen HubSpot affiliate entities accessing Customer Data across locations including the US, EU, Australia, Canada, Singapore, India, Japan, Colombia, Sweden, France, the UK, Belgium, Spain, and the Netherlands. Customers seeking to limit data access to specific Sub-Processors should review the HubSpot DPA to assess available contractual mechanisms.

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
    Contact HubSpot at privacy@hubspot.com to submit data-related requests or questions regarding Sub-Processor data access and applicable transfer mechanisms.

Cross-platform context

See how other platforms handle Advance DPA Consent to Infrastructure and Affiliate Sub-Processors and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
By agreeing to the DPA, you agree all of these Sub-Processors may have access to Customer Data.

Excerpt from HubSpot's Sub-Processors

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28(2), which permits controllers to grant general written authorization to processors to engage sub-processors, provided the processor informs the controller of intended additions or replacements and …

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 →

Provision details

Document information
Document
HubSpot Sub-Processors
Entity
HubSpot
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-015668
Document ID
CA-D-00932
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
be1ee395d61eaf157e884c8abd16fb6f7764b8b8dffdb3704efbafbd67a0364d
Analysis generated
July 6, 2026 23:16 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: HubSpot
Document: HubSpot Sub-Processors
Record ID: CA-P-015668
Captured: 2026-07-06 23:16:08 UTC
SHA-256: be1ee395d61eaf15…
URL: https://conductatlas.com/platform/hubspot/hubspot-sub-processors/provision/CA-P-015668/advance-dpa-consent-to-infrastructure-and-affiliate-sub-processors/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does HubSpot's Advance DPA Consent to Infrastructure and Affiliate Sub-Processors clause do?

This provision establishes a general authorization mechanism for sub-processor data access, meaning customers do not provide separate, per-Sub-Processor approval at the time each Sub-Processor is engaged. Under GDPR Article 28(2), general written authorization for sub-processors is permitted, but the controller must be informed of intended sub-processor changes and retain the ability to object; whether HubSpot's DPA implements that objection right …

How does this clause affect you?

This provision establishes that agreeing to HubSpot's DPA constitutes advance consent to infrastructure Sub-Processors and all fifteen HubSpot affiliate entities accessing Customer Data across locations including the US, EU, Australia, Canada, Singapore, India, Japan, Colombia, Sweden, France, the UK, Belgium, Spain, and the Netherlands. Customers seeking to limit data access to specific Sub-Processors should review the HubSpot DPA to assess …

Is ConductAtlas affiliated with HubSpot?

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