Provision record
HubSpot · HubSpot Terms of Service · View original document ↗

Customer Responsibility for Contact Data Legality

High severity High confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

The agreement requires the Customer to represent and warrant that all Customer Data provided to HubSpot has been lawfully collected, that the Customer holds all necessary rights and permissions to transfer and process that data, and that doing so does not violate applicable laws or third-party rights including privacy rights.

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 places the legal compliance burden for Contact Data on the Customer as data controller, creating direct exposure under GDPR, CCPA, and other applicable privacy laws if data is transferred to HubSpot without adequate lawful basis, consent, or required disclosures to data subjects.

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
May 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Change history

added Jun 17, 2026

This high-severity addition shifts legal responsibility to the customer for data legality and third-party rights compliance, with explicit coverage of export control laws.

View full change record →

Consumer impact (what this means for users)

This clause establishes that the Customer, not HubSpot, is responsible for ensuring that all Contact Data uploaded to the platform has been lawfully collected and that individuals whose data is processed have been appropriately notified. Under this provision, the Customer assumes warranty obligations regarding data legality that could create liability in the event of a privacy law violation.

How other platforms handle this

Google Cloud Medium

You can always contact your local data protection authority if you have concerns regarding your rights under local law.

ClickUp Medium

If you are an end user in a Workspace not owned by you and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization who owns your ClickUp Workspace.

Square Medium

to request that your data be transferred to a third party (data portability)

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Customer represents and warrants that it has obtained all necessary rights, releases and permissions to provide any Customer Data to HubSpot and to grant the rights granted to HubSpot in this Agreement, and that Customer Data and its transfer to and use by HubSpot as authorized by Customer under this Agreement will not violate any applicable laws (including those relating to export control and electronic communications) or rights of any third party, including without limitation, any intellectual property rights, rights of privacy, or rights of publicity.

Excerpt from HubSpot's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision directly engages GDPR Articles 5, 6, and 7 (lawfulness of processing, conditions for consent) for EU/EEA/UK customers, and CCPA Sections 1798.100 et seq.

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 →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

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-013014
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-013014
Captured: 2026-05-21 04:01:38 UTC
SHA-256: d0b7e297156535ff…
URL: https://conductatlas.com/platform/hubspot/hubspot-terms-of-service/provision/CA-P-013014/customer-responsibility-for-contact-data-legality/
Accessed: Sept. 8, 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 Responsibility for Contact Data Legality clause do?

This provision places the legal compliance burden for Contact Data on the Customer as data controller, creating direct exposure under GDPR, CCPA, and other applicable privacy laws if data is transferred to HubSpot without adequate lawful basis, consent, or required disclosures to data subjects.

How does this clause affect you?

This clause establishes that the Customer, not HubSpot, is responsible for ensuring that all Contact Data uploaded to the platform has been lawfully collected and that individuals whose data is processed have been appropriately notified. Under this provision, the Customer assumes warranty obligations regarding data legality that could create liability in the event of a privacy law violation.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with HubSpot?

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