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.
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 →How other platforms handle this
Cookies may also allow us and our service providers to collect data about your use of our services, including text you enter, screen recordings of your mouse movements, and other interactions as you browse and use our services, even if you don't have an account or Profile.
We collect certain information when you open an account such as your GitHub handle, name, email address, password, payment information and transaction information.
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
"if you use Substack to upload video content to YouTube, we collect account identifiers (including the email address associated with the account), video identifiers, and upload status information...Excerpt from Substack's Privacy Policy
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The clause states: “if you use Substack to upload video content to YouTube, we collect account identifiers (including the email address associated with the account), video identifiers, and upload status information...”
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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