If Substack is sold, merges with another company, or goes bankrupt, your personal information may be transferred to the new owner as part of that transaction.
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
Your personal data could be transferred to a different company with potentially different privacy practices if Substack undergoes a change of ownership, and the policy does not guarantee notice to users before such a transfer occurs.
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 →In the event of a sale, merger, or bankruptcy, your Substack personal data including subscription history, payment details, and message metadata could become an asset transferred to a new owner whose privacy practices you have not agreed to.
How other platforms handle this
If we're involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may disclose any of the information described in Section 2 above...
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
"Prospective sellers or buyers: We may share and/or transfer customer information in connection with the sale or merger of our business or assets (subject to local laws). Also, if we go out of business, enter bankruptcy, or go through some other change of control.Excerpt from Substack's Privacy Policy
REGULATORY LANDSCAPE: This provision is standard in commercial privacy policies but engages GDPR Article 6 requirements that any data transfer to a new controller following a business sale must have a valid legal basis.
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.
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Your personal data could be transferred to a different company with potentially different privacy practices if Substack undergoes a change of ownership, and the policy does not guarantee notice to users before such a transfer occurs.
In the event of a sale, merger, or bankruptcy, your Substack personal data including subscription history, payment details, and message metadata could become an asset transferred to a new owner whose privacy practices you have not agreed to.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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