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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 disclosure establishes that Substack does not warrant the security of user information and explicitly acknowledges the possibility of compromise at any time, which limits expectations of data protection.
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 are on notice that their information held by Substack is not guaranteed to be secure and may be compromised at any time due to unauthorized access, service failure, or other factors.
How other platforms handle this
We do not make any promises that these will be available 100% of the time. Our Services may be disrupted during certain periods, including, for example, as a result of scheduled or emergency maintenance.
We employ physical, electronic, and managerial measures to safeguard the data we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services.
NETFLIX DOES NOT GUARANTEE, REPRESENT, OR WARRANT THAT YOUR USE OF THE NETFLIX SERVICE WILL BE UNINTERRUPTED OR ERROR-FREE.
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"we cannot guarantee complete security. Unauthorized entry or use, failure of the services, or other factors may compromise the security of user information at any time.Excerpt from Substack's Privacy Policy
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
The disclosure establishes that Substack does not warrant the security of user information and explicitly acknowledges the possibility of compromise at any time, which limits expectations of data protection.
Users are on notice that their information held by Substack is not guaranteed to be secure and may be compromised at any time due to unauthorized access, service failure, or other factors.
ConductAtlas has identified this type of provision across 292 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.