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
You represent and warrant to us that the information you provide to us or any other user is accurate, including any information submitted through third-party sources (if applicable), and that you will update your account information as necessary to ensure its accuracy.
By using the Services, you have contracted with us through the Terms of Service, and we will process certain Personal Data to perform under that contract, including first and last name, email address, password, location information...
Making sure that any Authorised Users, employees, contractors, professional advisors or agents of ours or yours only have access to confidential information on a 'need-to-know basis'.
"Where we require Personal Information to comply with legal or contractual obligations, then provision of such information is mandatory: if such information is not provided, then we will not be able to manage our contractual relationship...Excerpt from Substack's Privacy Policy
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
The clause states: “Where we require Personal Information to comply with legal or contractual obligations, then provision of such information is mandatory: if such information is not provided, then we will not be able to manage our contractual relationship...”
ConductAtlas has identified this type of provision across 297 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.