HubSpot · HubSpot Terms of Service · View original document ↗

Data Processing Agreement Requirement

High severity Unique · 0 of 343 platforms
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Recent governance activity HubSpot recorded 6 documented changes in the last 30 days.
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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.

Recent Activity

This document changed recently

Medium Jul 2, 2026

The updated terms now explicitly state that AI is embedded throughout HubSpot's platform and is foundational to how subscription services operate. The agreement permits HubSpot to use customer data to train AI models, subject to contractual obligations. You can opt out of having your data used to train AI models by updating your settings in your HubSpot account.

View change record →

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

Figma Medium

If you are using our Services pursuant to a separate agreement with Figma that includes data processing terms, such as an enterprise agreement, those terms will govern the processing of personal data to the extent they conflict with this Privacy Policy.

Signal Medium

Signal can optionally discover which contacts in your address book are Signal users, using a service designed to protect the privacy of your contacts. Information from the contacts on your device may be cryptographically hashed and transmitted to the server in order to determine which of your contac...

Walmart Medium

We collect information about you when you shop in our stores, including through store cameras, loyalty programs, payment processing systems, and other in-store technologies. This information is used to improve store operations, loss prevention, and marketing.

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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 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-004872
Document ID
CA-D-00207
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d0b7e297156535ff7da47d2001c39ae52cac337ff0e1a6db64da8407bc2fa84b
Analysis generated
May 21, 2026 04:01 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: HubSpot
Document: HubSpot Terms of Service
Record ID: CA-P-004872
Captured: 2026-05-21 04:01:38 UTC
SHA-256: d0b7e297156535ff…
URL: https://conductatlas.com/platform/hubspot/hubspot-terms-of-service/data-processing-agreement-requirement/
Accessed: July 4, 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.