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

Privacy Rights Request and One-Month Response Commitment

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Document Record

What it is

The policy establishes that users may submit requests for access, correction, erasure, restriction, portability, and objection to processing, depending on applicable law. The most recent policy update added a one-month response commitment for certain privacy rights requests and the right to object to certain types of processing. Rights are subject to legal limitations including retention obligations.

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 establishes the procedural framework for user privacy rights requests, with a one-month response commitment added in the May 2026 update. The provision conditions the availability and scope of rights on applicable local law, meaning the rights available to a given user depend on their jurisdiction.

Interpretive note: The provision conditions rights on applicable local law without specifying which rights apply in which jurisdictions, and the right to object provision does not enumerate the specific processing activities subject to objection.

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 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

Under this clause, users in applicable jurisdictions may submit privacy rights requests to privacy@substackinc.com, and the policy commits to a one-month response timeline for certain requests. The agreement states that rights may be limited where Substack has a legal obligation to retain data, including after account deletion.

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 access, correction, erasure, restriction, portability, or objection to processing of your Personal Information. The policy states Substack will respond within one month.
  • Export Your Data
    Email privacy@substackinc.com to request a copy of your Personal Information or to request transfer of your information to another organization under applicable portability rights.

How other platforms handle this

Notion Medium

Depending on your location of residence, you may have the right to appeal our response to your request. In such circumstances, we will inform you of the right to appeal and the appeal process.

ZipRecruiter Medium

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.

Google Cloud Medium

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).

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

Excerpt from Substack's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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-013036
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-013036
Captured: 2026-05-21 04:18:30 UTC
SHA-256: a4d2324534904f4f…
URL: https://conductatlas.com/platform/substack/substack-privacy-policy/provision/CA-P-013036/privacy-rights-request-and-one-month-response-commitment/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

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Frequently Asked Questions

What does Substack's Privacy Rights Request and One-Month Response Commitment clause do?

This provision establishes the procedural framework for user privacy rights requests, with a one-month response commitment added in the May 2026 update. The provision conditions the availability and scope of rights on applicable local law, meaning the rights available to a given user depend on their jurisdiction.

How does this clause affect you?

Under this clause, users in applicable jurisdictions may submit privacy rights requests to privacy@substackinc.com, and the policy commits to a one-month response timeline for certain requests. The agreement states that rights may be limited where Substack has a legal obligation to retain data, including after account deletion.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 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.