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

Generative AI Service Provider Data Sharing

Medium severity Medium confidence Explicit document language Common · 287 of 352 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

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 →
Medium Apr 19, 2026

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 →

Clause Stability Stable

0
Changes
4
Months Monitored
May 8, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 4430 other provisions on other platforms.

Change history

modified Jun 5, 2026

Provision remains materially identical with no changes to content or severity.

View full change record →

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email privacy@substackinc.com to submit a request for erasure of your Personal Information or to request information about which service providers have received your data. The policy states Substack will respond within one month.

How other platforms handle this

Skillshare Medium

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.

Squarespace Medium

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.

Google Gemini Medium

Chats are disconnected from your account before being sent to service providers.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

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 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-006884
Document ID
CA-D-00178
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a4d2324534904f4fe245001d53f247ef46d8942c06d9e1fa0c0ef9aa893a52ee
Analysis generated
May 21, 2026 04:18 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-P-006884
Captured: 2026-05-21 04:18:30 UTC
SHA-256: a4d2324534904f4f…
URL: https://conductatlas.com/platform/substack/substack-privacy-policy/provision/CA-P-006884/generative-ai-service-provider-data-sharing/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Substack's Generative AI Service Provider Data Sharing clause do?

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.

How does this clause affect you?

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 many platforms have this type of clause?

ConductAtlas has identified this type of provision across 287 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.