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
The clause establishes a data controller relationship where Creators assume independent responsibility for personal information provided through publication interactions. This operationally means Substack's privacy commitments do not extend to Creator-controlled processing, requiring users to reference separate Creator privacy policies to understand information handling practices.
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 →Users' subscriber information is shared with Creators as a necessary operational function of publication delivery. Users are subject to each Creator's independent privacy practices and terms rather than Substack's stated privacy policy when their information is held by Creators.
How other platforms handle this
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
RedCard. We share information with our financial partners to operate the Target RedCard program.
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Substack has changed this document before.
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"when you subscribe to a Creator's publication, we provide them the information necessary (including your name and email address) to provide you their publication(s). Please note that Creators control their own publications; accordingly, when you interact with a Creator's publication in a way that requires your personal information, including when commenting on a publication that you have not subscribed to, that personal information is provided directly to the Creator. ... 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 Substack Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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The clause establishes a data controller relationship where Creators assume independent responsibility for personal information provided through publication interactions. This operationally means Substack's privacy commitments do not extend to Creator-controlled processing, requiring users to reference separate Creator privacy policies to understand information handling practices.
Users' subscriber information is shared with Creators as a necessary operational function of publication delivery. Users are subject to each Creator's independent privacy practices and terms rather than Substack's stated privacy policy when their information is held by Creators.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.