Provision record
Substack · Substack Privacy Policy · View original document ↗

Creators solely responsible for their own privacy compliance

High confidence Common · 290 of 343 platforms
Stay ahead of the changes
Track Substack and hear on the next check after its terms change. We check daily where we can, and show you where we can't.
Share 𝕏 Share in Share 🔒 PDF
ⓘ

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Generated by a model from the captured document; not read by a person

Users whose Personal Information is processed by Substack acting as a data processor for a Creator cannot rely on the Substack Privacy Policy to govern that processing, creating a potential gap in privacy protections.

⚠

Interpretive note: The clause contains two independent legal propositions: (1) Creators are responsible for their own privacy compliance; (2) the Privacy Policy does not apply to Substack's processing as a data processor on behalf of Creators. Both are stated in the canonical claim as they are directly linked and together constitute the primary legal effect.

Recent Activity

This document changed recently

Medium May 15, 2026

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 →
Medium May 5, 2026

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 →

Consumer impact (what this means for users)

Generated by a model from the captured document; not read by a person

When Substack processes a reader's Personal Information on behalf of a Creator, the Substack Privacy Policy does not apply to that processing, and the Creator bears responsibility for compliance.

How other platforms handle this

OpenAI

Third Party Services and Third Party Output are subject to their own terms, and we are not responsible for them.

Credit Karma

We are not responsible for any information that you agree to share with third parties in connection with Third Party Content or Third Party Services.

Kling AI

If any provisions from this Policy are in conflict with any applicable laws, such provisions will be replaced by provisions of the same purport that reflects the original intention of the provision, to the extent permissible under the applicable laws.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Creators using our services are responsible for their own privacy compliance and this Privacy Policy does not apply to any processing of your Personal Information by Substack as a data processor on behalf of any Creator.

Excerpt from Substack's Privacy Policy

Provision details

Document information
Document
Substack Privacy Policy
Entity
Substack
Date stated by the document
May 14, 2026
As printed in Substack’s text (version CA-V-007373), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
April 19, 2026
Text quoted from version
CA-V-004273, captured June 28, 2026
Record ID
CA-P-028165
Document ID
CA-D-000178
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-004273; extractor version not recorded, may not reproduce today)
71ddc259e5c57fb2e20d0374b0d56f85464085af02f0c9571bdde6b9270b442a
Analysis generated
May 21, 2026 04:18 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-004273, captured June 28, 2026 (checked Oct. 5, 2026)
Not the current version. The document's current version is CA-V-007373, captured Oct. 7, 2026; this clause has not been re-checked against it.
Citation Record
Entity: Substack
Document: Substack Privacy Policy
Record ID: CA-P-028165
Version: CA-V-004273
Captured: 2026-06-28 00:24:21 UTC
SHA-256: 71ddc259e5c57fb2…
URL: https://conductatlas.com/platform/substack/substack-privacy-policy/provision/CA-P-028165/creators-solely-responsible-for-their-own-privacy-compliance/
Accessed: Oct. 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

Get the weekly coverage letter

Companies change their terms without announcing it. We capture governance documents, compare each new version with the last, and publish what changed, with the source text behind it. One email a week on what we found and what we could not reach.

Frequently Asked Questions

What does Substack's Creators solely responsible for their own privacy compliance clause do?

Users whose Personal Information is processed by Substack acting as a data processor for a Creator cannot rely on the Substack Privacy Policy to govern that processing, creating a potential gap in privacy protections.

How does this clause affect you?

When Substack processes a reader's Personal Information on behalf of a Creator, the Substack Privacy Policy does not apply to that processing, and the Creator bears responsibility for compliance.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Substack?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.