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
Send You Promotional and Marketing Materials Consent (where required by law) Legitimate Interests when consent is not required by law (specifically our interests in marketing features and products that may interest you...)
In some cases we will seek your consent to send you marketing communications.
We may use your Personal Data to send you information about the services provided by the ZipRecruiter Group; provided, however that we will obtain consent to do so where required by applicable law.
"we will send you, based on your consent (if required), direct marketing communication in relation to our relevant services, or other services provided by us, our affiliates and carefully selected partners.Excerpt from Substack's Privacy Policy
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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The clause states: “we will send you, based on your consent (if required), direct marketing communication in relation to our relevant services, or other services provided by us, our affiliates and carefully selected partners.”
ConductAtlas has identified this type of provision across 279 platforms. See the full comparison.
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