Substack · Substack Privacy Policy · View original document ↗

De-identified Data Sharing with Unspecified Trusted Partners

Medium severity Unique · 0 of 325 platforms
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Recent governance activity Substack recorded 3 documented changes in the last 30 days.
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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)

The standard for de-identification is contested, and sharing anonymized data with unspecified 'trusted partners' without user consent or the ability to identify the recipients creates meaningful re-identification risk and limits consumer accountability.

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 exploitati…

Consumer impact (what this means for users)

Substack collects a wide range of personal data including payment details, location, device identifiers, and direct message contents, and shares this data with service providers including generative AI services, creators, and industry child safety organizations. The lack of end-to-end encryption on direct messages is a meaningful privacy limitation for users who may assume private communications are protected, as Substack personnel may access message content and recipients can retain messages indefinitely even after deletion requests. You can request access to, correction of, or deletion of your personal data by emailing privacy@substackinc.com, and you can opt out of direct marketing through the unsubscribe mechanism in any marketing communication.

How other platforms handle this

HubSpot Medium

We may share your personal data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We may also share your personal data with advertising partners to display relevant advertising to y...

Steam Medium

In order to provide you with services, Valve needs to share some data with the publisher or developer of the game (for example to verify your ownership of the game and register your Steam ID with the publisher), or with other third parties that Valve works with to provide services to you. Valve will...

Zoom Medium

Zoom may share personal data with third-party advertising partners and analytics providers to deliver targeted advertising and measure the effectiveness of advertising campaigns. This may include sharing identifiers, device information, and behavioral data with partners such as advertising networks.

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▸ View Original Clause Language DOCUMENT RECORD
"
In certain cases, we may anonymize your Personal Information in such a way that you can no longer be identified as an individual, and we reserve the right to use and share such anonymized information to trusted partners not specified here. However, we never disclose aggregated or de-identified information in a manner that could identify you as an individual.

— Excerpt from Substack's Substack Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
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
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Substack Privacy Policy
Entity
Substack
Document last updated
May 5, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 11, 2026
Record ID
CA-P-006885
Document ID
CA-D-00178
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
69d115f06fc1e4f75cab0566ca01b279d70be9b2c99c4c197c67a2922d1622b7
Analysis generated
May 11, 2026 04:34 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-P-006885
Captured: 2026-05-11 04:34:06 UTC
SHA-256: 69d115f06fc1e4f7…
URL: https://conductatlas.com/platform/substack/substack-privacy-policy/de-identified-data-sharing-with-unspecified-trusted-partners/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Substack's De-identified Data Sharing with Unspecified Trusted Partners clause do?

The standard for de-identification is contested, and sharing anonymized data with unspecified 'trusted partners' without user consent or the ability to identify the recipients creates meaningful re-identification risk and limits consumer accountability.

Is ConductAtlas affiliated with Substack?

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