Correct, except you can use textures.com as long as you mention you sourced your textures from them not selling them as apart of a texture pack (so they can be on your model, just not as a substance designer pack or just a pack of their textures for sale as 'textures'). You need to put a clause (as a text file with the model or on your description, or both) that says:
"One or more textures on this 3D model have been created with photographs from Textures.com. These photographs may not be redistributed by default; please visit www.textures.com for more information."
You can read in more detail here:
https://www.textures.com/contact-terms-of-use.html
6.2