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
Your personal information may be transferred to countries other than where you live, such as, for example, to our servers in the US.
Under Section 1798.83, Ancestry currently does not share any Personal Information with third parties for their own direct marketing purposes.
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
"Substack is established in the US and uses service providers established both in the US and in other countries to process Personal Information as described in this Privacy Policy. As such, your Personal Information may be shared internationally.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: “Substack is established in the US and uses service providers established both in the US and in other countries to process Personal Information as described in this Privacy Policy. As such, your Personal Information may be shared internationally.”
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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