The policy discloses that Substack shares Personal Information with third-party service providers including generative AI services, analytics providers, and cloud computing services. The policy does not identify specific generative AI providers or describe which categories of Personal Information are shared with AI service providers.
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 authorizes sharing of Personal Information with generative AI service providers as part of Substack's service provider relationships. The absence of specific provider names and data category limitations for AI services creates uncertainty about the scope of Personal Information that may be processed by third-party AI systems on Substack's behalf.
Interpretive note: The policy does not specify which categories of Personal Information are shared with generative AI service providers or identify the specific providers involved, creating interpretive uncertainty about the scope of this sharing.
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 →Provision remains materially identical with no changes to content or severity.
View full change record →Under this clause, Personal Information collected by Substack may be shared with generative AI service providers as part of Substack's third-party service provider relationships. The policy does not specify which AI providers receive Personal Information or which data categories are involved.
How other platforms handle this
We share Personal Data with vendors, service providers, and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service.
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.
Chats are disconnected from your account before being sent to service providers.
"Our Service Providers: We share your Personal Information with third-party service providers that provide services on our behalf; for example, we use Stripe (a third party payment provider) to receive and process your credit card transactions for us. Such third parties further include, but are not limited to, providers of: website hosting; maintenance services; email services; security services; generative AI services; content delivery networks; customer support operations and software services; traffic and usage analytics services; and cloud storage and computing services.Excerpt from Substack's Privacy Policy
1.
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.
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.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
This provision authorizes sharing of Personal Information with generative AI service providers as part of Substack's service provider relationships. The absence of specific provider names and data category limitations for AI services creates uncertainty about the scope of Personal Information that may be processed by third-party AI systems on Substack's behalf.
Under this clause, Personal Information collected by Substack may be shared with generative AI service providers as part of Substack's third-party service provider relationships. The policy does not specify which AI providers receive Personal Information or which data categories are involved.
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.