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
Under Section 1798.83, Ancestry currently does not share any Personal Information with third parties for their own direct marketing purposes.
Gemini Apps may share your precise location data with another Google service, like Google Maps, to fulfill your request.
In some cases, in order to show you more relevant ads, we disclose with social media platforms and other advertising partners, information about actions you take on our websites and apps, such as which pages you visit and which ads you saw.
"we may anonymize your Personal Information in such a way that you can no longer be identified as an individual, and we reserve the right to use and share such anonymized information to trusted partners not specified here.Excerpt from Substack's Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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The clause states: “we may anonymize your Personal Information in such a way that you can no longer be identified as an individual, and we reserve the right to use and share such anonymized information to trusted partners not specified here.”
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.