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 one-month deadline gives users a defined window within which Substack must act on privacy rights requests, creating an enforceable time-bound obligation.
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 →Users who submit a privacy rights request are entitled to a response from Substack within one month of that request being received.
How other platforms handle this
where the EU GDPR or UK GDPR applies, we will respond within one calendar month of receiving a verifiable request, and where your request is complex...we may extend that period by up to a further two months.
You may make a verifiable consumer request related to your personal information twice per 12-month period.
When you exercise any of your applicable legal rights to access, amend, or delete your personal information, we may request additional information from you for the purpose of confirming your identity.
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"We will respond to any request to exercise your rights within one month of receipt.— Excerpt from Substack's Substack Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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The one-month deadline gives users a defined window within which Substack must act on privacy rights requests, creating an enforceable time-bound obligation.
Users who submit a privacy rights request are entitled to a response from Substack within one month of that request being received.
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