Last Modified: April 7, 2020
Our online Subscription Service allows users (typically small to medium size businesses) to create and share marketing, sales and customer service content. The Subscription Service can also be used to help organize sales data about a company’s sales pipeline (e.g., leads, customers, deals, etc.). The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers' servers. HubSpot provides the Subscription Service to our customers for their own marketing, sales, CRM, and customer service needs.
Our customers use the Subscription Service to build webpages that people can visit to learn more about their business. When customers use the Subscription Service, they may collect Personal Data such as first and last name, email address, physical address, or phone number. HubSpot does not control the content of these webpages or the types of Personal Data that our customers may choose to collect or manage using the Subscription Service. That Personal Data is controlled by them and is used, disclosed and protected by them according to their privacy policies. HubSpot processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers.
We have no direct relationship with individuals who provide Personal Information to our customers. Our customers control and are responsible for correcting, deleting or updating information they have collected from using the Subscription Service. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage.
We employ other third-party service providers to provide services on our behalf to visitors to our websites, our customers, and Users of the Subscription Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies. Examples of these third-party service providers can be found on this page.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by HubSpot on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
i. Third Parties
We may provide links within our sites and services to the sites or services of third parties. We are not responsible for the collection, use, monitoring, storage or sharing of any Personal Data by such third parties, and we encourage you to review those third parties' privacy notices and ask them questions about their privacy practices as they relate to you.
ii. Google Integrations
If you choose to integrate your Gmail or any other G Suite application with the Subscription Service you may use the following integrations and allow HubSpot access to your Google user data:
iii. HubSpot Sales Outlook Add-In
If you use the Outlook integration with the HubSpot Product, the Subscription Service will have access to information associated with your account, including contacts, emails, calendar, distribution lists, subject lines, and URLs of tracked links from your email, if you use the email tracking functionality. The HubSpot Product will scan the content of your emails to identify which emails you have elected to track in order to provide you with the Notifications feature. The Subscription Service will store, replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and message bodies. Correspondences you track will be visible to other Users on your Subscription.
iv. Generic Inbox Connection (IMAP)
If you connect your email account via IMAP (or Generic Inbox Connection), the Subscription Service will have access only to email address, password, server information, email metadata, and message bodies. Additionally, connecting your Outlook account via IMAP does not require you to connect any other Microsoft applications.
v. Documents Tool
If you use the Documents feature of the Subscription Service, files that you upload using this ‘Documents’ feature are stored by us and shared with other users of your HubSpot CRM team.
If you choose to use the shared inbox feature of our Conversations functionality you understand that any User may have access to or visibility into the contents of this inbox.
vii. Data Practices and Service Data
We automatically collect metrics and information about how Users interact with and use the Subscription Service. We use this information to develop and improve the Subscription Services and the Consulting Services, and to inform our sales and marketing strategies. We may share or publish this service data with third parties in an aggregated and anonymized manner, but we will not include any Customer Data or identify Users.
If you access the Subscription Services via our mobile applications, we may also collect your device model and version, device identifier, and OS version. We may send you push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
We use Customer Data in an anonymized manner for machine learning that supports certain product features and functionality within the Subscription Service.
When you use the Subscription Service, we automatically collect log files. These log files contain information about a Users’ IT system, a User’s IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times, and referring website addresses. We use this information to ensure the optimal operation of the Subscription Service and for security purposes. We may link log files to Personal Data such as name, email address, address, and phone number for these purposes.
You can log in to our site using a Single Sign-on (SSO) service like your Google account. This service will authenticate your identity and provide you the option to share certain Personal Data with us such as your name.
viii. Enrichment Data
When you add company records to the HubSpot CRM, we populate certain fields with company level Enrichment Data. You’ll recognize Enrichment Data in the HubSpot CRM because it is flagged with a grey information icon (or highlighted in some other way), which on hover, identifies the property as being filled from HubSpot’s Insights database. These properties may include information such as company name, company location, and company address. This data is obtained from public and third party sources. We do not use Customer Data to populate Enrichment Data.
ix. Integrations with the HubSpot Platform
You may choose to connect any number of applications or integrations, including our certified partner applications, with your HubSpot account. If you give an integration provider access to your HubSpot account then your use of these integrations is subject to the service terms and privacy terms made available by that integrator. We are not responsible for third party integrators and in no case are such integration providers our sub-processors. For more information on our partners, please see: https://ecosystem.hubspot.com/marketplace/apps.
i. Email Template Tools
In addition to the Inbox Integration described above, if you opt to use our template building tools, the Subscription Service will scan the content of your sent emails to identify possible templates for use by Users of your HubSpot account.
ii. Call Transcription
The ‘Call Transcription’ feature allows you to transcribe calls that you record with Sales Hub products. We use Google Cloud Platform’s Cloud Speech-to-Text API and Google Cloud Storage to provide Call Transcription, which requires us to share call data with Google for use, analysis, and storage by Google.
In order to use the Call Transcription feature you must consent to Google’s use of your call data via an in-app modal. If you do not consent, we are unable to provide the Call Transcription service to you. You are responsible for compliance with all call recording laws and obtaining any required consents from callers.
i. HubSpot Video
ii. HubSpot Tracking Code for WordPress Plugin
To connect your WordPress installation with your HubSpot account, we may use WordPress account information such as your email address to authenticate the connection. You grant permission to us and our licensors to collect data from your WordPress instance only as necessary to provide the Subscription Service and Consulting Services to you and as permitted by this the Customer Terms of Service.
iii. Content Membership
The Content Membership functionality allows you to gate certain content to Contacts based on an authentication list and passwords. Passwords are not stored in the Subscription Service and are hashed. We do not have access to your Contacts’ passwords.
i. Youtube Integration
If you use the YouTube Integration, you agree to be bound by YouTube's terms, available at: https://www.youtube.com/t/terms.
If you choose to connect your YouTube account with our Social Tool (subject to your product tier), as part of posting to YouTube through the Subscription Service, the HubSpot platform will store your posts and publish them at the scheduled time as selected by you. Additionally, the Subscription Service will add tracking code to any post URL generated through the HubSpot Platform, solely for the purpose of tracking clicks. The Subscription Service stores comments and replies on your posts, as well as analytics for the performance of your posts.
ii. Twitter Integration
You may choose to integrate your Twitter account with the HubSpot Platform (depending on product tier) in order to manage your Twitter. As part of posting Tweets through the Subscription Service, the HubSpot platform will store your Tweets and post Tweets upon their scheduled time as selected by you. Additionally, the Subscription Service will add tracking code to any Tweet URL generated through the HubSpot Platform, solely for the purpose of tracking clicks. The Subscription Service will store replies to and analytics for the performance of your Tweets.
iii. LinkedIn Integrations
Your use of the LinkedIn Ads integration is also subject to the terms and conditions provided by LinkedIn, available at: https://www.linkedin.com/legal/sas-terms. The Subscription Service will be able to view and manage your account, as well as store your LinkedIn Ads account number. As part of the integration, the Subscription Service receives user token with permissions on ad accounts and pages. The Subscription Service can view but does not store all the LinkedIn ads accounts and pages that you have permission for. LinkedIn will share with the Subscription Service: settings details (e.g., name, budget, bid strategy, creative) and performance metrics (impressions, clicks, etc.) for all campaigns, ad sets, and ads in the ad accounts the user has “connected” to the Subscription Service.
If you choose to sync leads, the Subscription Service will receive webhook updates when a new lead form submission occurs on a Page the user has “connected” to your account. The Subscription Service will pull all lead submissions for Pages the user has connected. The Subscription Service will log these submissions as form submissions in the CRM.
If you choose to connect your LinkedIn account with our Social Tool (subject to your product tier), as part of posting to LinkedIn through the Subscription Service, the HubSpot platform will store your posts and publish only at the time you schedule. Additionally, the Subscription Service will add tracking code to any post URL generated through the HubSpot Platform, solely for the purpose of tracking clicks. The Subscription Service stores comments and replies on your posts, as well as analytics for the performance of your posts.
As part of any LinkedIn integration the Subscription Service will store your account name and profile picture.
iv. Google AdWords Integration
Your use of the Google AdWords integration is subject to Google’s terms at: https://support.google.com/adspolicy/answer/54818. The Subscription Service will be able to view and manage your account, and stores your Google Ads account number. As part of the integration, the Subscription Service receives user token with permissions on ad accounts and pages. The Subscription Service can view but does not store all the Google ad accounts that you have permission for. Google will share with the Subscription Service: settings details (e.g., name, budget, bid strategy, creative) and performance metrics (impressions, clicks, etc.) for all campaigns, ad sets, and ads in the ad accounts the user has “connected” to the Subscription Service.
If you choose to sync leads, the Subscription Service will receive webhook updates when a new lead form submission occurs and will log these submissions as form submissions in the CRM.
v. Facebook and Instagram Integrations
If you share any data from your HubSpot Account with Facebook, as part of our Ads integration, Facebook’s ad terms will apply: https://www.facebook.com/legal/self_service_ads_terms. As part of the integration, the Subscription Service receives user token with permissions on ad accounts and pages. The Subscription Service can view but does not store all the ad accounts and pages that you have permission for. Facebook will share with the Subscription Service: settings details (e.g., name, budget, bid strategy, creative) and performance metrics (impressions, clicks, etc.) for all campaigns, ad sets, and ads in the ad accounts the user has “connected” to the Subscription Service.
If you choose to sync leads, the Subscription Service will receive webhook updates when a new lead form submission occurs on a page a user has connected to your account. The Subscription Service will pull all lead submissions for Pages the user has connected. The Subscription Service will log these submissions as form submissions in the CRM.
Facebook and Instagram
If you choose to connect your Facebook and/or Instagram account with our Social Tool (subject to your product tier), as part of posting to Facebook and/or Instagram through the Subscription Service, the HubSpot platform will store your posts and publish only at the time you schedule. Additionally, the Subscription Service will add tracking code to any post URL generated through the HubSpot Platform, solely for the purpose of tracking clicks. The Subscription Service stores comments and replies on your posts, as well as analytics for the performance of your posts
Ad Network Pixel and Tags
The Subscription Service will receive the selected ad network (for all Ad Network) pixel/tag identification as part of connecting you account to that network. The Subscription Service will automatically place this pixel/tag on the user’s website pages where HubSpot tracking code is present. This pixel/tag sends and tracks information about your website visitors back to the network, enabling conversion tracking and website audience creation.
If you are a customer, prospect, or otherwise interact with one of our Customers and would no longer like to be contacted by one of our customers that use our Subscription Service, please contact the customer that you interact with directly. If you want to access, correct, amend, or delete data controlled by a HubSpot customer, you should direct your query to the HubSpot Customer (the data controller). We will work with customers to respond to data subject requests as outlined in our DPA.
You may request the deletion of your HubSpot account or Subscription Service by sending a request to firstname.lastname@example.org. You should also review our DPA to understand our obligations as a processor of your data and how we comply with relevant data protection laws.
Customer Data collected during your use of the Subscription Service is retained in accordance with the provisions of the DPA and is retained for as long as you have a paid Subscription and/or remain an active customer in your portal. Your data is deleted upon your written request or after an established period following the termination of all customer agreements. In general, Customer Data is deleted after your paid Subscription ends and your portal becomes inactive.
International Transfers within HubSpot’s Entities
To facilitate our global operations, we transfer information to either Ireland or the United States and allow access to that information from countries in which the HubSpot Affilates have operations for the purposes described in this policy.
International transfers to third parties
Privacy Shield Notice
HubSpot, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. HubSpot is committed to the Framworks' applicable principles regarding transfers of Personal Data received from the European Economic Area (EEA), the United Kingdom, and Switzerland, in reliance on each Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
HubSpot is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. HubSpot complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA, the United Kingdom, and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, HubSpot is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, HubSpot may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You may direct any inquiries or complaints related to our Privacy Shield compliance to email@example.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Data Protection Officer (DPO)
25 First Street, 2nd Floor
Cambridge, MA 02141 USA