HubSpot · HubSpot Terms of Service · View original document ↗

Customer Data Ownership and Controller Responsibility

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Document Record

What it is

You own your customer data in HubSpot, but you are entirely responsible for making sure you legally collected it and have the right to use it — HubSpot is not responsible if your data collection practices violate the law.

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)

The provision allocates data ownership to the customer while establishing the customer's sole responsibility for data accuracy, quality, and legality. This framework clarifies that HubSpot does not claim ownership interest in customer data, but conditions the customer's use of the services on the customer's warranty of proper data acquisition and authority to license the data to HubSpot.

Consumer impact (what this means for users)

Business customers assume full legal responsibility for the lawfulness of all data they upload into HubSpot, including compliance with GDPR, CCPA, and CAN-SPAM — creating significant regulatory exposure for businesses that fail to audit their data sources.

How other platforms handle this

DocuSign Medium

When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For certain products such as Docusign's Contract Lifecycle Management (CLM) and Identity products, we may act as a processor and as a controller in certa...

Runway Medium

Runway is considered the "data controller" of the "personal data" (as defined under the General Data Protection Regulation) we handle under this Privacy Policy. In other words, Runway is responsible for deciding how to collect, use, and disclose personal data, subject to applicable law. The laws of ...

Anthropic Medium

This Privacy Policy does not apply where Anthropic acts as a data processor and processes personal data on behalf of commercial customers using Anthropic's Commercial Services – for example, your employer has provisioned you a Claude for Work account, or you're using an app that is powered on the ba...

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▸ View Original Clause Language DOCUMENT RECORD
"
As between HubSpot and Customer, Customer retains all right, title, and interest in Customer Data. Customer is solely responsible for the accuracy, quality, and legality of Customer Data and the means by which Customer acquired Customer Data. Customer represents and warrants that it has all necessary rights, consents, and permissions to submit Customer Data to the Services and to grant HubSpot the rights set forth herein.

— Excerpt from HubSpot's HubSpot Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY FRAMEWORK: This provision directly implicates GDPR Art. 6 (lawful basis for processing) and Art. 7 (conditions for consent), with the Customer designated as data controller bearing primary compliance obligations. CCPA §1798.100 imposes parallel obligations on businesses collecting California resident personal information. CAN-SPAM Act (15 U.S.C. §7701) and TCPA (47 U.S.C. §227) are implicated for email and SMS marketing data. Enforcement authorities: EU DPAs (lead: Irish DPC), California Privacy Protection Agency, FTC, and FCC for TCPA. (2)

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces against unfair or deceptive data collection practices under FTC Act Section 5, relevant when businesses misrepresent their data sourcing to end users.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
HubSpot Terms of Service
Entity
HubSpot
Document last updated
May 5, 2026
Tracking information
First tracked
April 18, 2026
Last verified
April 18, 2026
Record ID
CA-P-002966
Document ID
CA-D-00207
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9927299c7582997f7d7d4ec9af87291e8942c38b96b84ff4e2ea6e359778795c
Analysis generated
April 18, 2026 11:17 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: HubSpot
Document: HubSpot Terms of Service
Record ID: CA-P-002966
Captured: 2026-04-18 11:17:02 UTC
SHA-256: 9927299c7582997f…
URL: https://conductatlas.com/platform/hubspot/hubspot-terms-of-service/customer-data-ownership-and-controller-responsibility/
Accessed: June 17, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does HubSpot's Customer Data Ownership and Controller Responsibility clause do?

The provision allocates data ownership to the customer while establishing the customer's sole responsibility for data accuracy, quality, and legality. This framework clarifies that HubSpot does not claim ownership interest in customer data, but conditions the customer's use of the services on the customer's warranty of proper data acquisition and authority to license the data to HubSpot.

How does this clause affect you?

Business customers assume full legal responsibility for the lawfulness of all data they upload into HubSpot, including compliance with GDPR, CCPA, and CAN-SPAM — creating significant regulatory exposure for businesses that fail to audit their data sources.

Is ConductAtlas affiliated with HubSpot?

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