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
This disclosure establishes that account identifiers are shared outside Substack with third-party organizations, even absent a legal order, for a defined child safety purpose.
Interpretive note: The excerpt is a fragment lacking its governing verb and modal qualifier (e.g., 'may share' or 'will share'), so the precise conditionality of the sharing obligation cannot be confirmed from this excerpt alone. The companion clause 28098 supplies fuller language. Confidence is medium because the standalone fragment does not itself establish the permission structure.
The updated policy discloses that Substack obtains additional information from third parties and sources beyond what it directly collects from you on the platform. This third-party information is combined with platform data to provide what Substack describes as more relevant and safer experiences, and to improve platform analytics. The policy also clarifies that Substack shares account identifiers with child safety industry consortia and receives information from them to detect CSAM. You can review Substack's full privacy policy to understand which third parties may be sources of this information and how your data may be combined with external sources.
View change record →The updated policy discloses that Substack shares account identifiers (email addresses and usernames) with trusted child safety organizations to detect and prevent online child sexual exploitation and abuse. Users now have the right to object to processing of their personal information for personalization purposes on grounds relating to their particular situation, and Substack commits to responding to privacy rights requests within one month. The policy also clarifies that while recipients of direct messages may retain them independently, the platform may restrict your access to messages when other users delete or block you. You can exercise your right to object to personalization processing by contacting privacy@substackinc.com.
View change record →Users' account identifiers may be shared with trusted industry child safety consortia without the user's individual consent for each such share.
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"to share account identifiers with trusted industry child safety consortia for the detection and prevention of online child sexual exploitation and abuse (OCSEA)Excerpt from Substack's Privacy Policy
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This disclosure establishes that account identifiers are shared outside Substack with third-party organizations, even absent a legal order, for a defined child safety purpose.
Users' account identifiers may be shared with trusted industry child safety consortia without the user's individual consent for each such share.
ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.