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 use of 'may be entitled' conditions these rights on unstated eligibility criteria, meaning they are not guaranteed to every user in every circumstance.
Interpretive note: The phrase 'may be entitled' is a significant legal qualifier indicating that these rights are conditional, not universal. This qualifier is preserved across all fields.
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 →Depending on applicable entitlements, users may have rights to access, correct, erase, restrict, or transfer their Personal Information held by Substack.
How other platforms handle this
You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you...
Access information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic information transferred to another party.
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
"you may be entitled to ask Substack for a copy of your Personal Information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organizations.Excerpt from Substack's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The use of 'may be entitled' conditions these rights on unstated eligibility criteria, meaning they are not guaranteed to every user in every circumstance.
Depending on applicable entitlements, users may have rights to access, correct, erase, restrict, or transfer their Personal Information held by Substack.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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