Provision record
Substack · Substack Privacy Policy · View original document ↗

Creators solely responsible for their own privacy compliance

High severity High confidence Explicit document language Common · 298 of 352 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Users whose Personal Information is processed by Substack acting as a data processor for a Creator cannot rely on the Substack Privacy Policy to govern that processing, creating a potential gap in privacy protections.

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Interpretive note: The clause contains two independent legal propositions: (1) Creators are responsible for their own privacy compliance; (2) the Privacy Policy does not apply to Substack's processing as a data processor on behalf of Creators. Both are stated in the canonical claim as they are directly linked and together constitute the primary legal effect.

Recent Activity

This document changed recently

Medium May 5, 2026

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 →

Consumer impact (what this means for users)

When Substack processes a reader's Personal Information on behalf of a Creator, the Substack Privacy Policy does not apply to that processing, and the Creator bears responsibility for compliance.

How other platforms handle this

Minecraft Medium

You make it clear that you (not us) are responsible for anything that happens during your event

Shopify Medium

If you use these services, you need to respect how the supply chain works and what terms are asked of you.

Grubhub Medium

To the extent that the rules or terms of those promotions concerning the treatment of your personal information conflict with this Privacy Policy, the rules of those promotions will control.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Creators using our services are responsible for their own privacy compliance and this Privacy Policy does not apply to any processing of your Personal Information by Substack as a data processor on behalf of any Creator.

Excerpt from Substack's Privacy Policy

Provision details

Document information
Document
Substack Privacy Policy
Entity
Substack
Date stated by the document
May 14, 2026
As printed in Substack’s text (version CA-V-007373), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
April 19, 2026
Text quoted from version
CA-V-004273, captured June 28, 2026
Record ID
CA-P-028165
Document ID
CA-D-000178
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-004273; extractor version not recorded, may not reproduce today)
71ddc259e5c57fb2e20d0374b0d56f85464085af02f0c9571bdde6b9270b442a
Analysis generated
May 21, 2026 04:18 UTC
Methodology
Evidence
✓ Excerpt found verbatim in version CA-V-004273 (checked Oct. 5, 2026)
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-P-028165
Version: CA-V-004273
Captured: 2026-06-28 00:24:21 UTC
SHA-256: 71ddc259e5c57fb2…
URL: https://conductatlas.com/platform/substack/substack-privacy-policy/provision/CA-P-028165/creators-solely-responsible-for-their-own-privacy-compliance/
Accessed: Oct. 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 Substack's Creators solely responsible for their own privacy compliance clause do?

Users whose Personal Information is processed by Substack acting as a data processor for a Creator cannot rely on the Substack Privacy Policy to govern that processing, creating a potential gap in privacy protections.

How does this clause affect you?

When Substack processes a reader's Personal Information on behalf of a Creator, the Substack Privacy Policy does not apply to that processing, and the Creator bears responsibility for compliance.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 298 platforms. See the full comparison.

Is ConductAtlas affiliated with Substack?

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