You have rights to access, correct, delete, or transfer your personal data held by Substack depending on where you live, and Substack commits to responding to these requests within one month.
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
The one-month response commitment, newly added in this policy update, gives users a concrete service level expectation for privacy rights requests, which is aligned with GDPR Article 12 requirements and provides an enforceable benchmark for EU users.
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 renamed from 'Privacy Rights and One-Month Response Commitment' to 'Privacy Rights Request and One-Month Response Commitment' with identical content.
View full change record →Users who submit data access, correction, or deletion requests to Substack can expect a response within one month under this policy, though the policy notes that applicable law may limit the scope of these rights in certain circumstances.
How other platforms handle this
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).
Not be Discriminated Against by us for exercising your privacy rights.
"Depending on applicable local laws, you may be entitled to ask Substack for a copy of your Personal Information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organizations. You may also have rights to object to some processing activities or to request restriction of some processing activities. Where we have asked for your consent to process your Personal Information, you may also have the right to withdraw this consent. These rights may be limited in some situations or in accordance with applicable law – for example, we cannot delete your Personal Information when we can demonstrate that we have a legal obligation to retain it. We will respond to any request to exercise your rights within one month of receipt.Excerpt from Substack's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages GDPR Article 12 (response timelines), Article 15 (access), Article 16 (rectification), Article 17 (erasure), Article 18 (restriction), Article 20 (portability), and Article 21 (objection).
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The one-month response commitment, newly added in this policy update, gives users a concrete service level expectation for privacy rights requests, which is aligned with GDPR Article 12 requirements and provides an enforceable benchmark for EU users.
Users who submit data access, correction, or deletion requests to Substack can expect a response within one month under this policy, though the policy notes that applicable law may limit the scope of these rights in certain circumstances.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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