HubSpot · HubSpot Terms of Service · View original document ↗

Data Processing Agreement Requirement

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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 incorporation by reference establishes a separate contractual framework governing data processing obligations, liability allocation, and compliance responsibilities under European data protection law. This mechanism ensures that data processing activities are subject to statutorily-mandated terms rather than remaining within the general service agreement, affecting the regulatory compliance posture of both parties.

Consumer impact (what this means for users)

Customers processing personal data subject to GDPR or similar legislation become bound by the terms of the separate DPA without requiring a separate signature or affirmative acceptance beyond continued service use. The customer's obligations and HubSpot's responsibilities regarding data security, transfers, sub-processing, and regulatory compliance are specified in the referenced DPA rather than the primary service agreement.

How other platforms handle this

Adyen Medium

In providing the services, Adyen will process personal data in accordance with its Privacy Policy and applicable data protection laws, including the General Data Protection Regulation. You are responsible for ensuring that you have the necessary consents and legal bases to share personal data with A...

Dun & Bradstreet Medium

We process many types of data to support business decisioning, including data about people, businesses, organizations, places, economic activity, sustainability, legal, and other significant business events, and third-party risks. Some of the data we process is considered personal data. Some of the ...

Apple App Store Medium

When you use Siri, Apple collects data such as your voice input, contacts, and other information to fulfill your request. If you opt in to help improve Siri, a small portion of audio recordings may be analyzed by Apple employees and contractors who are subject to confidentiality requirements. You ca...

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▸ View Original Clause Language DOCUMENT RECORD
"
To the extent Customer uses the Services to process personal data subject to GDPR, the UK GDPR, or other applicable data protection legislation, the parties agree to be bound by HubSpot's Data Processing Agreement ('DPA'), which is incorporated herein by reference and available at legal.hubspot.com/dpa. Customer's use of the Services to process such personal data constitutes Customer's agreement to the DPA.

— Excerpt from HubSpot's HubSpot Terms of Service

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
May 9, 2026
Last verified
May 9, 2026
Record ID
CA-P-004872
Document ID
CA-D-00207
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fe8ba7ca9a80e255f49bcc03fd3d4cf922c263ff1879581e19704a1350fb3524
Analysis generated
May 9, 2026 21:58 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: HubSpot
Document: HubSpot Terms of Service
Record ID: CA-P-004872
Captured: 2026-05-09 21:58:44 UTC
SHA-256: fe8ba7ca9a80e255…
URL: https://conductatlas.com/platform/hubspot/hubspot-terms-of-service/data-processing-agreement-requirement/
Accessed: May 20, 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 Data Processing Agreement Requirement clause do?

The incorporation by reference establishes a separate contractual framework governing data processing obligations, liability allocation, and compliance responsibilities under European data protection law. This mechanism ensures that data processing activities are subject to statutorily-mandated terms rather than remaining within the general service agreement, affecting the regulatory compliance posture of both parties.

How does this clause affect you?

Customers processing personal data subject to GDPR or similar legislation become bound by the terms of the separate DPA without requiring a separate signature or affirmative acceptance beyond continued service use. The customer's obligations and HubSpot's responsibilities regarding data security, transfers, sub-processing, and regulatory compliance are specified in the referenced DPA rather than the primary service agreement.

Is ConductAtlas affiliated with HubSpot?

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