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
The clause establishes a permissive right for Substack to disclose identifiable account data to third-party organizations outside any individual legal process, for a defined child safety purpose.
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' email addresses and usernames may be disclosed to trusted industry child safety organizations without user-specific authorization, within the stated purpose.
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
Monitoring
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"We may share account identifiers (such as email addresses and usernames) with trusted industry child safety organizations for the purpose of detecting and preventing online child sexual exploitation and abuse (OCSEA).— Excerpt from Substack's Substack Privacy Policy
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The clause establishes a permissive right for Substack to disclose identifiable account data to third-party organizations outside any individual legal process, for a defined child safety purpose.
Users' email addresses and usernames may be disclosed to trusted industry child safety organizations without user-specific authorization, within the stated purpose.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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