The policy establishes that when Substack processes subscriber Personal Information on behalf of a Creator, that processing falls outside the scope of this Privacy Policy and is instead governed by the Creator's own privacy practices. Subscribers who interact with Creator publications are directed to the Creator's own terms and privacy policies for information about how that data is used.
This analysis describes what Substack'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 a data controller boundary that places responsibility for subscriber data governance on individual Creators when Substack acts as a processor on their behalf. The practical implication is that subscriber privacy rights and data handling practices vary across publications, and Substack's policy does not govern those interactions, which may require subscribers to review multiple separate privacy policies.
Interpretive note: The operational boundary between Substack as controller and Substack as processor on behalf of Creators may be subject to regulatory interpretation under GDPR and CCPA, particularly where Substack infrastructure processes subscriber data in ways that benefit both Substack and Creators simultaneously.
Substack now discloses that it shares account identifiers, such as email addresses and usernames, with trusted industry child safety organizations to detect and prevent online child sexual exploitation and abuse. The policy also establishes that Substack will respond to privacy rights requests within one month, or up to three months for complex requests, providing more certainty about response timelines. Additionally, the policy clarifies that direct message recipients may retain messages even if you request deletion or delete your account, which is now explicitly stated rather than implied.
View change record →The updated policy no longer commits to responding to privacy rights requests within one month or within three months for complex requests. This removes a procedural timeline that previously bound Substack's response obligations. Additionally, the explicit disclosure that Substack shares account identifiers with child safety consortia to detect online child sexual exploitation has been removed from the policy, though the practice itself is not stated to have ended. The direct message retention language is now framed more directly: recipients may retain messages even if you request deletion or close your account.
View change record →This new provision clarifies the scope limitations of Substack's privacy policy and transfers responsibility for Creator data practices to individual creators, potentially reducing Substack's liability.
View full change record →Under this clause, Personal Information provided when subscribing to or interacting with a Creator's publication is governed by that Creator's own privacy policy rather than Substack's, meaning the protections and rights described in this policy may not apply to Creator-level data processing. The agreement states that when commenting on a publication the user has not subscribed to, that personal information is provided directly to the Creator.
How other platforms handle this
Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data...we will provide you with the data controller's contact information, so you can contact them directly.
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
"This Privacy Policy only applies to the processing of your Personal Information by Substack as a data controller, meaning where we process your Personal Information for our purposes. This Privacy Policy does not apply to any processing of your Personal Information by Substack as a data processor on behalf of a Creator. Creators will have their own privacy practices governing their use of Personal Information as outlined in their own terms of use and/or privacy policies.Excerpt from Substack's Privacy Policy
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Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision establishes a data controller boundary that places responsibility for subscriber data governance on individual Creators when Substack acts as a processor on their behalf. The practical implication is that subscriber privacy rights and data handling practices vary across publications, and Substack's policy does not govern those interactions, which may require subscribers to review multiple separate privacy policies.
Under this clause, Personal Information provided when subscribing to or interacting with a Creator's publication is governed by that Creator's own privacy policy rather than Substack's, meaning the protections and rights described in this policy may not apply to Creator-level data processing. The agreement states that when commenting on a publication the user has not subscribed to, that personal information …
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.