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 updated policy discloses that Substack obtains additional information from third parties and sources beyond what it directly collects from you on the platform. This third-party information is combined with platform data to provide what Substack describes as more relevant and safer experiences, and to improve platform analytics. The policy also clarifies that Substack shares account identifiers with child safety industry consortia and receives information from them to detect CSAM. You can review Substack's full privacy policy to understand which third parties may be sources of this information and how your data may be combined with external sources.
View change record →The updated policy discloses that Substack shares account identifiers (email addresses and usernames) with trusted child safety organizations to detect and prevent online child sexual exploitation and abuse. Users now have the right to object to processing of their personal information for personalization purposes on grounds relating to their particular situation, and Substack commits to responding to privacy rights requests within one month. The policy also clarifies that while recipients of direct messages may retain them independently, the platform may restrict your access to messages when other users delete or block you. You can exercise your right to object to personalization processing by contacting privacy@substackinc.com.
View change record →How other platforms handle this
We may continue to retain some information even after you delete your account if we are required to do so in order to comply with applicable laws.
Those posts and profile information may remain on such sites even after you delete your account.
After you submit a request to delete your account, we initiate a deletion process to safely and completely remove your data from our servers or retain it only in anonymized form.
"In some instances, this may mean that we are able to retain data even if you withdraw your consent or you delete your account.Excerpt from Substack's Privacy Policy
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The clause states: “In some instances, this may mean that we are able to retain data even if you withdraw your consent or you delete your account.”
ConductAtlas has identified this type of provision across 268 platforms. See the full comparison.
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