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 entity | HubSpot, Inc. |
|---|---|
| HQ | US |
| Parent company | — |
| Ultimate ownership | — |
| EU contracting entity | HubSpot Ireland Limited (and 4 other EU entities by country) |
| LEI | 529900BLNVEW0MVKJB37 |
| US CLOUD Act reach | Contracting entity incorporated in the US |
| Source | legal.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
| Region | EU data location | Minimum plan | Source | Observed |
|---|---|---|---|---|
| EU | Paid upgrade | Starter, Professional or Enterprise | knowledge.hubspot.com | 2026-09-18 |
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
| Subprocessor | Country | If hosted in the EU | Purpose |
|---|---|---|---|
| Ably Realtime Ltd. | US, IE, DE, AU, CA | IE, DE | Conversation & Chat Functionality |
| Amazon Web Services, Inc. | US, EU | EU | AI Service Provider |
| Amazon Web Services, Inc. | US, DE, AU, CA | DE | Hosting & Infrastructure |
| Baseten Labs, Inc. | US, EU | EU | AI Service Provider |
| Bright Data Ltd. | US | US | Web Search Results |
| Cloudflare, Inc. | US | — | Content Delivery Network |
| ConvertAPI, UAB | US, NL, DE, AU, CA | NL, DE | File Functionality |
| Dropbox, Inc. | US, DE | DE | E-Signature Functionality |
| Exa Labs, Inc. | US | US | Web Search Results |
| Google LLC | US, EU | EU | AI Service Provider |
| Google LLC | US, DE | DE | Infrastructure - Regional Data Processing |
| Google LLC | US | US | reCAPTCHA |
| Hyperdoc, Inc. | US, DE | DE | Meeting recordings and transcripts |
| Litmus Software, Inc. | US | US | Email Functionality |
| Meta Platforms, Inc. | US | US | Conversation Functionality |
| Mux, Inc. | US | US | Video Functionality |
| OpenAI, L.L.C. | US, EU, CH | EU, CH | AI Service Provider |
| Snowflake Inc. | US, DE, AU, CA | DE | Infrastructure |
| 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)
| Company | Country | Purpose |
|---|---|---|
| HubSpot Asia Pte. Ltd. | SG | Services & Support |
| HubSpot Australia Pty. Ltd. | AU | Services & Support |
| HubSpot Belgium NV | BE | Services & Support |
| HubSpot Canada Inc. | CA | Services & Support |
| HubSpot France S.A.S. | FR | Services & Support |
| HubSpot Germany GmbH | DE | Services & Support |
| HubSpot India Private Limited | IN | Services & Support |
| HubSpot Ireland Ltd | IE | Services & Support |
| HubSpot Japan KK | JP | Services & Support |
| HubSpot Latin America, S.A.S. | CO | Services & Support |
| HubSpot Netherlands B.V. | NL | Services & Support |
| HubSpot Spain, S.L. | ES | Services & Support |
| HubSpot Sweden | SE | Services & Support |
| HubSpot UK Holdings Ltd. | GB | Services & Support |
| HubSpot, Inc. | US | Services & 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
| Term | What the agreement says |
|---|---|
| Transfer mechanism | EU-U.S. DPF |
| Transfer mechanism | SCC module 1 |
| Transfer mechanism | SCC module 2 |
| Transfer mechanism | SCC module 3 |
| Transfer mechanism | Swiss FADP clauses |
| Transfer mechanism | UK Addendum |
| Notice of new subprocessors | 30 days prior to change, by email to customers who opt in via subscription form |
| Notice of new subprocessors | At 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 one | Customer 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 subprocessors | Data 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 notification | without undue delay, no later than 72 hours after becoming aware |
| Deletion when the service ends | delete 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 back | vendor 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 subjects | reasonable 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 |
| Audit | Audit 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 |
| Audit | CCPA 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 |
| Audit | Compliance 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 |
| Audit | SCC Clause 8.9 audit rights exercised by instructing vendor to comply with the 'Demonstration of Compliance' section of the DPA |
| Processing on your instructions | Processes 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 staff | Authorized personnel subject to appropriate contractual or statutory confidentiality obligations |
| Security measures | Appropriate 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.
| Plans | Term | What the page says | Source | Observed |
|---|---|---|---|---|
| All plans HubSpot AI features (all products and plans) | Training on your data | Not used AI service providers are not permitted to use customer data for model training | knowledge.hubspot.com | 2026-10-28 |
| All plans HubSpot AI features (all products and plans) | Zero data retention | With its model providers zero data retention enforced with AI service providers wherever possible | knowledge.hubspot.com | 2026-10-28 |
| All plans HubSpot AI features (all products and plans) | EU processing | In the EU EEA processing locations per AI service provider, shown by data center location on the Sub-Processors Page | knowledge.hubspot.com | 2026-10-28 |
| All plans HubSpot AI features (all products and plans) | Model providers | AWS | knowledge.hubspot.com | 2026-10-28 |
| All plans HubSpot AI features (all products and plans) | Model providers | knowledge.hubspot.com | 2026-10-28 | |
| All plans HubSpot AI features (all products and plans) | Model providers | OpenAI | knowledge.hubspot.com | 2026-10-28 |
| Business HubSpot's AI | Training on your data | Used 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.com | 2026-10-28 |
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.
| Scheme | Status | Scope | Source | Observed |
|---|---|---|---|---|
| CIS Critical Security Controls | Claimed | HubSpot's security program | legal.hubspot.com | 2026-10-05 |
| OWASP Top 10 | Claimed | HubSpot's security program | legal.hubspot.com | 2026-10-05 |
| SOC 2 Type 2 · SOC2T2 | Available on request | — | legal.hubspot.com | 2026-10-05 |
| SOC3 | Claimed | — | legal.hubspot.com | 2026-10-05 |
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
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| Data Privacy Framework List (US) | EU-U.S. Data Privacy Framework · HubSpot, Inc. | Active | non-HR data | 2026-11-06 | 2026-10-05 |
| Data Privacy Framework List (US) | Swiss-U.S. Data Privacy Framework · HubSpot, Inc. | Active | non-HR data | 2026-11-06 | 2026-10-05 |
| Data Privacy Framework List (US) | UK Extension to the EU-U.S. DPF · HubSpot, Inc. | Active | non-HR data | 2026-11-06 | 2026-10-05 |
| EU Cloud Code of Conduct (GDPR Art. 40) | HubSpot (hubspot.com) · HubSpot | adherent | Level 2 | 2027-06-24 | 2026-10-09 |
| Global LEI Index (GLEIF) | HubSpot Germany GmbH · HubSpot Germany GmbH | LAPSED | DE | 2025-01-12 | 2026-10-08 |
| Global LEI Index (GLEIF) | HUBSPOT IRELAND LIMITED · HUBSPOT IRELAND LIMITED | ISSUED | IE | 2027-03-12 | 2026-10-08 |
| Global LEI Index (GLEIF) | HUBSPOT, INC. · HUBSPOT, INC. | ISSUED | US-DE | 2027-03-12 | 2026-10-08 |
- ACN qualified cloud (Italy): checked 2026-11-02, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- ISO 27001 on the basis of IT-Grundschutz (BSI, Germany): checked 2026-11-09, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- CISPE Data Protection Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- DORA critical ICT third-party providers (ESAs): checked 2026-10-26, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- Data Privacy Framework List (US): checked 2026-11-02, 3 entries under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- ENS certificates of conformity (CCN, Spain): checked 2026-11-02, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-02, 1 entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- FedRAMP Marketplace (US): checked 2026-11-02, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- GPAI Code of Practice signatories (European Commission): checked 2026-11-09, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-02, no entry under HubSpot; HubSpot Ireland Limited; HubSpot Ireland Ltd; HubSpot, Inc.
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
| Product | Support period | State | SBOM | Source | Observed |
|---|---|---|---|---|---|
| HubSpot (SaaS) | — | Service only | unknown | hubspot.com | 2026-09-18 |
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
- Marketing Hub
- Sales Hub
- Service Hub
- Content Hub
- Data Hub
- Revenue Hub
- Agent Hub
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.
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| ai | Public | full | 200 | 2026-10-28 |
| ai-2 | Public | full | 200 | 2026-10-28 |
| dpa | Public | full | 200 | 2026-10-09 |
| dpa-de | Public | full | 200 | 2026-10-19 |
| products | Public | full | 200 | 2026-10-29 |
| subprocessors | Public | full | 200 | 2026-09-18 |
| tia | Public | full | 200 | 2026-10-20 |
History
| Detected | What moved | Why | Source |
|---|---|---|---|
| 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 page | knowledge.hubspot.com |
Every reviewed change across the registry, newest first: vendor changes.