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
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).
If you are an end user in a Workspace not owned by you and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization who owns your ClickUp Workspace.
"Where your request is complex or you have made a number of requests, we may extend this period by a further two months and will notify you of any such extension...within one month of receipt of your request.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 clause states: “Where your request is complex or you have made a number of requests, we may extend this period by a further two months and will notify you of any such extension...within one month of receipt of your request.”
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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