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
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.
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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.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
If we rely on certain legal bases (such as "legal obligation" or "contractual necessity") and you do not provide us with your Personal Data, we may not be able to lawfully provide you services.
"This Privacy Policy does not apply to any processing of your Personal Information by Substack as a data processor on behalf of a Creator.Excerpt from Substack's Privacy Policy
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The clause states: “This Privacy Policy does not apply to any processing of your Personal Information by Substack as a data processor on behalf of a Creator.”
ConductAtlas has identified this type of provision across 298 platforms. See the full comparison.
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