When you subscribe to or comment on a publication on Substack, the creator of that publication receives your name and email address, and that creator then controls how they use your personal information according to their own privacy policies.
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
Your personal data does not stay within Substack's control once you engage with a creator's publication; the creator receives it and handles it under their own terms, which users may not have separately reviewed.
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 detailed provision explaining creator data sharing was replaced with the more general 'Creator as Independent Data Controller' provision, potentially reducing transparency around specific data sharing scenarios.
View full change record →Subscribing to or commenting on any Substack publication transfers your name and email address to the individual creator, who operates under their own privacy practices that may differ significantly from Substack's policy and may not offer equivalent protections.
How other platforms handle this
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
"Creators: 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.Excerpt from Substack's Privacy Policy
REGULATORY LANDSCAPE: This provision is operationally significant under GDPR because it designates creators as separate data controllers, not processors, for the personal data they receive.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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Your personal data does not stay within Substack's control once you engage with a creator's publication; the creator receives it and handles it under their own terms, which users may not have separately reviewed.
Subscribing to or commenting on any Substack publication transfers your name and email address to the individual creator, who operates under their own privacy practices that may differ significantly from Substack's policy and may not offer equivalent protections.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.