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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
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"These rights may be limited in some situations or in accordance with applicable law – for example, we cannot delete your Personal Information when we can demonstrate that we have a legal obligation to retain it.Excerpt from Substack's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
The clause states: “These rights may be limited in some situations or in accordance with applicable law – for example, we cannot delete your Personal Information when we can demonstrate that we have a legal obligation to retain it.”
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.