eucsoft

HubSpot

CRM marketing · hubspot.com · last read 2026-11-09

Products HubSpot names as its own: Marketing Hub, Sales Hub, Service Hub, Content Hub, Data Hub, Revenue Hub, Agent Hub Source and date

At a glance

Is HubSpot GDPR compliant?
No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what HubSpot itself publishes, each answer linked to its source and the date we read it.
Does HubSpot have a data processing agreement (DPA)?
Yes. HubSpot publishes a data processing agreement at legal.hubspot.com. It gives 30 days' notice before a new subprocessor is added. It commits to telling you of a personal data breach within 72 hours. Source and date
Which version of the HubSpot DPA is current?
On 2026-11-09, HubSpot's DPA at legal.hubspot.com printed “Last Modified: September 16, 2026”. Source and date
Does HubSpot have a SOC 2 report?
HubSpot says a SOC 2 Type 2 report is available on request. In HubSpot's words: “Download our SOC3 and SOC 2 Type 2, our latest penetration test summaries, the HubSpot Security Overview, and more above.” We read this on 2026-10-05. Source and date
Where is HubSpot's trust center?
HubSpot publishes a page it calls “Trust Center” at trust.hubspot.com. Some of its documents sit behind a request or sign-in: the page says “Get Access”. The page mentions SOC 2, a penetration test, subprocessors and security questionnaires. We read it on 2026-11-03. Source and date
Does HubSpot use your data to train AI models?
For every plan (HubSpot AI features (all products and plans)): AI service providers are not permitted to use customer data for model training. For business plans (HubSpot's AI): Customer data may be used to improve HubSpot's models; opting out is always available. AI service providers are contractually required not to train on HubSpot customer data. Source and date
Does HubSpot offer zero data retention?
For every plan (HubSpot AI features (all products and plans)): zero data retention enforced with AI service providers wherever possible. Source and date
Can HubSpot process AI data in the EU?
For every plan (HubSpot AI features (all products and plans)): EEA processing locations per AI service provider, shown by data center location on the Sub-Processors Page. Source and date
How does HubSpot transfer personal data out of the EU?
HubSpot's agreement relies on the EU standard contractual clauses, the EU-U.S. Data Privacy Framework and the UK transfer addendum. HubSpot, Inc. is on the official Data Privacy Framework List (status: Active). Source and date
Does HubSpot offer EU data residency?
An EU location exists but requires a paid plan or add-on. Plan it needs: Starter, Professional or Enterprise. Source and date
Who are HubSpot's subprocessors?
HubSpot lists 20 third-party subprocessors; 20 of them name at least one processing country outside the EEA. We last read the list on 2026-10-05. Source and date
How do you report a security vulnerability to HubSpot?
HubSpot publishes a security.txt at www.hubspot.com naming [email protected]. The file falls short of RFC 9116: Expires not a date: 2034-06-01:00:00.000Z. Source and date

The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.

Identity

Legal entityHubSpot, Inc.
HQUS
Parent company—
Ultimate ownership—
EU contracting entityHubSpot Ireland Limited (and 4 other EU entities by country)
LEI529900BLNVEW0MVKJB37
US CLOUD Act reachContracting entity incorporated in the US
Sourcelegal.hubspot.com · 2026-10-08

Legal entity from the vendor's own terms. LEI, registered country and parent company from the Global LEI Index (GLEIF); ownership is left empty where GLEIF names no parent. The CLOUD Act row is arithmetic over those countries, not an assessment of risk.

HubSpot data residency

RegionEU data locationMinimum planSourceObserved
EUPaid upgradeStarter, Professional or Enterpriseknowledge.hubspot.com2026-09-18

EU: EU hosting is AWS in Germany. Page states accounts with a Starter, Professional or Enterprise subscription can change data centre, and accounts on free tools must upgrade to do so. HubSpot also states support staff outside the region may access data during security incidents, and that apps and sub-processors may move data outside the hosting location.

The same question for every vendor: where SaaS vendors store EU data.

HubSpot's subprocessor list names AWS and Google for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.

Subprocessor chain

20 third parties · 15 of the vendor's own group companies · 20 with a country outside the EEA · all read 2026-10-05

SubprocessorCountryIf hosted in the EUPurpose
Ably Realtime Ltd.US, IE, DE, AU, CAIE, DEConversation & Chat Functionality
Amazon Web Services, Inc.US, EUEUAI Service Provider
Amazon Web Services, Inc.US, DE, AU, CADEHosting & Infrastructure
Baseten Labs, Inc.US, EUEUAI Service Provider
Bright Data Ltd.USUSWeb Search Results
Cloudflare, Inc.US—Content Delivery Network
ConvertAPI, UABUS, NL, DE, AU, CANL, DEFile Functionality
Dropbox, Inc.US, DEDEE-Signature Functionality
Exa Labs, Inc.USUSWeb Search Results
Google LLCUS, EUEUAI Service Provider
Google LLCUS, DEDEInfrastructure - Regional Data Processing
Google LLCUSUSreCAPTCHA
Hyperdoc, Inc.US, DEDEMeeting recordings and transcripts
Litmus Software, Inc.USUSEmail Functionality
Meta Platforms, Inc.USUSConversation Functionality
Mux, Inc.USUSVideo Functionality
OpenAI, L.L.C.US, EU, CHEU, CHAI Service Provider
Snowflake Inc.US, DE, AU, CADEInfrastructure
Stripe, Inc.US—Payment Processor; Support Revenue Hub products and services
Twilio Inc.US—Calling and SMS Functionality; Support HubSpot calling and SMS functionality
HubSpot's own group companies listed as subprocessors (15)
CompanyCountryPurpose
HubSpot Asia Pte. Ltd.SGServices & Support
HubSpot Australia Pty. Ltd.AUServices & Support
HubSpot Belgium NVBEServices & Support
HubSpot Canada Inc.CAServices & Support
HubSpot France S.A.S.FRServices & Support
HubSpot Germany GmbHDEServices & Support
HubSpot India Private LimitedINServices & Support
HubSpot Ireland LtdIEServices & Support
HubSpot Japan KKJPServices & Support
HubSpot Latin America, S.A.S.COServices & Support
HubSpot Netherlands B.V.NLServices & Support
HubSpot Spain, S.L.ESServices & Support
HubSpot SwedenSEServices & Support
HubSpot UK Holdings Ltd.GBServices & Support
HubSpot, Inc.USServices & Support

The count outside the EEA is arithmetic over the country column, not a judgement about lawfulness. A transfer outside the EEA can be perfectly lawful; whether this one is depends on your use, not on the vendor.

Every subprocessor in the registry, and which vendors name it: subprocessors.

Processing terms

From the vendor's data processing agreement · read 2026-10-09 · legal.hubspot.com

TermWhat the agreement says
Transfer mechanismEU-U.S. DPF
Transfer mechanismSCC module 1
Transfer mechanismSCC module 2
Transfer mechanismSCC module 3
Transfer mechanismSwiss FADP clauses
Transfer mechanismUK Addendum
Notice of new subprocessors30 days prior to change, by email to customers who opt in via subscription form
Notice of new subprocessorsAt least 30 days prior to changes to the Sub-Processors Page, by email to customers who opt in via the subscription form
If you object to oneCustomer may object on reasonable data-protection grounds within 30 days of notice; the parties discuss in good faith. If they cannot resolve it, HubSpot decides either not to appoint the sub-processor or to let the customer suspend or terminate the affected service without liability
Obligations passed to subprocessorsData protection terms imposed on Sub-Processors providing at least the same level of protection as this DPA (to the extent applicable to their services); vendor remains responsible for Sub-Processors' compliance
Breach notificationwithout undue delay, no later than 72 hours after becoming aware
Deletion when the service endsdelete or return all Customer Data on termination or expiration per the Product Specific Terms; exceptions for legally required retention and for back-up archives, which are isolated, protected from further processing and deleted per the vendor's deletion practices
Getting your data backvendor gives reasonable assistance, at the customer's cost, with retrieving Customer Data during the Subscription Term; it notifies the customer of costs in advance
Requests from data subjectsreasonable assistance on written request (at customer's cost) where customer cannot address request via the service; requests sent directly to the vendor are promptly passed to the customer and the data subject is told to submit the request to the customer
AuditAudit rights are exercised through the listed measures: SOC 2 report and penetration-test summaries on request (confidential, also at trust.hubspot.com) and written answers to reasonable information requests once per calendar year unless noncompliance is suspected. Audits and inspections by customer or its auditor apply where required by law
AuditCCPA only: customer may take reasonable and appropriate steps to ensure California Personal Information is used consistently with its CCPA obligations, and to stop and remediate unauthorized use on notice
AuditCompliance review under the 'Demonstration of Compliance' section; the customer must take reasonable measures to limit impact by combining audit requests for itself and its Permitted Affiliates into one single audit
AuditSCC Clause 8.9 audit rights exercised by instructing vendor to comply with the 'Demonstration of Compliance' section of the DPA
Processing on your instructionsProcesses Customer Personal Data only for the purposes described in the DPA or as otherwise agreed within the scope of Customer's lawful Instructions, except where required by applicable law
Confidentiality of staffAuthorized personnel subject to appropriate contractual or statutory confidentiality obligations
Security measuresAppropriate technical and organizational measures as described in Annex 2 ("Security Measures")

Terms as the agreement states them. Where it is silent on a term, there is no row; that is not a statement that the vendor does not offer it.

Which version applies

On 2026-11-09, the agreement printed: Last Modified: September 16, 2026 at legal.hubspot.com

Last updated 2026-09-16

This version is in our copies from 2026-10-09.

These terms side by side for every vendor: data processing agreements compared. What vendors give you for a transfer impact assessment: transfer impact assessments.

AI and your data

What HubSpot's own pages state about the data you send its AI products, plan by plan. Compared with other vendors on AI vendors and your data.

PlansTermWhat the page saysSourceObserved
All plans
HubSpot AI features (all products and plans)
Training on your dataNot used AI service providers are not permitted to use customer data for model trainingknowledge.hubspot.com2026-10-28
All plans
HubSpot AI features (all products and plans)
Zero data retentionWith its model providers zero data retention enforced with AI service providers wherever possibleknowledge.hubspot.com2026-10-28
All plans
HubSpot AI features (all products and plans)
EU processingIn the EU EEA processing locations per AI service provider, shown by data center location on the Sub-Processors Pageknowledge.hubspot.com2026-10-28
All plans
HubSpot AI features (all products and plans)
Model providersAWSknowledge.hubspot.com2026-10-28
All plans
HubSpot AI features (all products and plans)
Model providersGoogleknowledge.hubspot.com2026-10-28
All plans
HubSpot AI features (all products and plans)
Model providersOpenAIknowledge.hubspot.com2026-10-28
Business
HubSpot's AI
Training on your dataUsed unless you opt out Customer data may be used to improve HubSpot's models; opting out is always available. AI service providers are contractually required not to train on HubSpot customer data.hubspot.com2026-10-28

Assurance

Does HubSpot have a SOC 2 report?

HubSpot says a SOC 2 Type 2 report is available on request. We read this on 2026-10-05.

  • Available on request “Download our SOC3 and SOC 2 Type 2, our latest penetration test summaries, the HubSpot Security Overview, and more above.”

Source: legal.hubspot.com, 2026-10-05

Of the 114 vendors in this registry whose own pages mention SOC 2, 57 say the report is available on request, 1 links to the report itself, and 56 state it without saying how to get it. The type is the one the vendor names.

SchemeStatusScopeSourceObserved
CIS Critical Security ControlsClaimedHubSpot's security programlegal.hubspot.com2026-10-05
OWASP Top 10ClaimedHubSpot's security programlegal.hubspot.com2026-10-05
SOC 2 Type 2 · SOC2T2Available on request—legal.hubspot.com2026-10-05
SOC3Claimed—legal.hubspot.com2026-10-05

Claimed means the vendor asserts the scheme on its own page and offers nothing further. Available on request means the report or certificate exists but sits behind a request, a login or an NDA. Neither is a certificate we have seen. That is a distinction an auditor makes, so we make it too.

SecNumCloud, C5, ENS and HDS for every vendor, with the pages for ISO standards, SOC 2 and TISAX: certifications compared.

Official registers

RegisterOffering, as the register names itStatusLevelValid untilObserved
Data Privacy Framework List (US)EU-U.S. Data Privacy Framework · HubSpot, Inc.Activenon-HR data2026-11-062026-10-05
Data Privacy Framework List (US)Swiss-U.S. Data Privacy Framework · HubSpot, Inc.Activenon-HR data2026-11-062026-10-05
Data Privacy Framework List (US)UK Extension to the EU-U.S. DPF · HubSpot, Inc.Activenon-HR data2026-11-062026-10-05
EU Cloud Code of Conduct (GDPR Art. 40)HubSpot (hubspot.com) · HubSpotadherentLevel 22027-06-242026-10-09
Global LEI Index (GLEIF)HubSpot Germany GmbH · HubSpot Germany GmbHLAPSEDDE2025-01-122026-10-08
Global LEI Index (GLEIF)HUBSPOT IRELAND LIMITED · HUBSPOT IRELAND LIMITEDISSUEDIE2027-03-122026-10-08
Global LEI Index (GLEIF)HUBSPOT, INC. · HUBSPOT, INC.ISSUEDUS-DE2027-03-122026-10-08

What the authority publishes, not what the vendor claims. An entry covers the offering it names and nothing else: a FedRAMP authorisation for a government edition says nothing about the commercial service. No entry is not a finding about security - most vendors never apply - and an entry filed under a name not listed above would not have been found.

What an entry on the Data Privacy Framework List covers, and which vendors hold one: EU-US Data Privacy Framework.

Support window

ProductSupport periodStateSBOMSourceObserved
HubSpot (SaaS)—Service onlyunknownhubspot.com2026-09-18

Vulnerability reporting: [email protected] (security.txt, Expires not a date: 2034-06-01:00:00.000Z; read 2026-10-17)

How other vendors publish theirs: security.txt across the registry.

Products

As HubSpot's own list names them. Each fact on this page comes from the document cited beside it; a product named here is not necessarily covered by every one of those documents. Source: hubspot.com, 2026-10-29.

Documents

Where is HubSpot's trust center?

HubSpot publishes a page it calls “Trust Center” at trust.hubspot.com. Some of its documents sit behind a request or sign-in. The page mentions SOC 2, a penetration test, subprocessors and security questionnaires. We read it on 2026-11-03. Open trust.hubspot.com

  • Name “Customers can visit the HubSpot Trust Center to access security and compliance documentation, browse FAQs, and review additional trust resources.”
  • Request step “Get Access”

Source: trust.hubspot.com, 2026-11-03. Read from the page's text, without a model; every vendor's trust center.

What we read, how it was disclosed, and when.
DocumentDisclosureTranscriptionHTTPObserved
aiPublicfull2002026-10-28
ai-2Publicfull2002026-10-28
dpaPublicfull2002026-10-09
dpa-dePublicfull2002026-10-19
productsPublicfull2002026-10-29
subprocessorsPublicfull2002026-09-18
tiaPublicfull2002026-10-20

History

DetectedWhat movedWhySource
2026-09-18
EU data location Terms not stated → Paid upgrade
Minimum plan set to Starter, Professional or Enterprise
Note rewritten
we read a better pageknowledge.hubspot.com

Every reviewed change across the registry, newest first: vendor changes.