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 clause establishes that data collection and processing is triggered broadly by any interaction or subscription, covering both free and paid services.
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 →Any interaction with Substack or its services, or any subscription whether paid or unpaid, results in Substack collecting and processing the user's Personal Information.
How other platforms handle this
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
if you place a restaurant order, our restaurant partner will collect and process your credit card or other payment information in order to fulfill the order.
Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number... Collected: Yes.
"We collect and process Personal Information about you when you interact with us and our services, as well as when you subscribe to any of our paid or unpaid services.Excerpt from Substack's Privacy Policy
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The clause establishes that data collection and processing is triggered broadly by any interaction or subscription, covering both free and paid services.
Any interaction with Substack or its services, or any subscription whether paid or unpaid, results in Substack collecting and processing the user's Personal Information.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Substack.