This provision establishes a two-tier structure for feature-specific Sub-Processors: those that apply by default when certain features are used, and those that apply only when a customer actively opts in. For opt-in Sub-Processors, HubSpot states it will notify customers before activation. Customers may avoid a feature-specific Sub-Processor by choosing not to use the associated feature or integration.
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 that certain Sub-Processors are activated automatically when default features are used, without a specific opt-in action at the time of Sub-Processor engagement. The document does not specify which listed feature-specific Sub-Processors are default versus opt-in, meaning customers must determine this through feature-level review rather than from this document alone.
Interpretive note: The document does not specify which of the listed feature-specific Sub-Processors are classified as default versus opt-in, requiring customers to obtain this information through feature-level review or direct inquiry with HubSpot.
Under this provision, some feature-specific Sub-Processors will process Customer Data by default when certain HubSpot features are active, while others require customer opt-in. Customers who wish to avoid a particular Sub-Processor may do so by not using the associated feature or integration, but must first identify which Sub-Processors are default versus opt-in.
Cross-platform context
See how other platforms handle Opt-In versus Default Feature-Specific Sub-Processors and similar clauses.
Compare across platforms →"Some of our features and integrations require the use of additional Sub-Processors. 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. In either case, you may choose not to use the Applicable Service provided by these Sub-Processors. We will notify you before you turn on a feature or install an integration that requires support from an opt-in Sub-Processor.Excerpt from HubSpot's Sub-Processors
(1) REGULATORY LANDSCAPE: This provision engages GDPR principles of data minimization and purpose limitation, as default-active Sub-Processors may process Customer Data without a specific opt-in decision at the feature level.
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This provision establishes that certain Sub-Processors are activated automatically when default features are used, without a specific opt-in action at the time of Sub-Processor engagement. The document does not specify which listed feature-specific Sub-Processors are default versus opt-in, meaning customers must determine this through feature-level review rather than from this document alone.
Under this provision, some feature-specific Sub-Processors will process Customer Data by default when certain HubSpot features are active, while others require customer opt-in. Customers who wish to avoid a particular Sub-Processor may do so by not using the associated feature or integration, but must first identify which Sub-Processors are default versus opt-in.
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