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.
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 →Users' account identifiers may be shared with trusted industry child safety consortia without the user's individual consent for each such share.
How other platforms handle this
if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services
Chats are disconnected from your account before being sent to service providers.
disclosure is required by a third-party to complete a transaction initiated by the user
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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 Substack 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 289 platforms. See the full comparison.
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