Privacy Policy

20200101_rev01 · COMPARED WITH 20190305_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE

Full text changes — 20190305_rev01 to 20200101_rev01

11## Spotify Privacy Policy
22
3Effective as of May 25, 2018
3Effective as of January 1, 2020
44
551 [Introduction]()
662 [About this Policy]()
773 [Your rights and your preferences: Giving you choice and control]()
84 [How do we collect your personal data?]()
95 [What personal data do we collect from you?]()
106 [What do we use your personal data for?]()
117 [Sharing your personal data]()
128 [Data retention and deletion]()
139 [Transfer to other countries]()
1410 [Links]()
1511 [Keeping your data safe]()
1612 [Children]()
1713 [Changes to this Privacy Policy]()
1814 [How to contact us]()
84 [Personal data we collect from you]()
95 [What we use your personal data for]()
106 [Sharing your personal data]()
117 [Data retention and deletion]()
128 [Transfer to other countries]()
139 [Links]()
1410 [Keeping your personal data safe]()
1511 [Children]()
1612 [Changes to this Policy]()
1713 [How to contact us]()
1918
2019## 1\. Introduction
2120
2221Thanks for choosing Spotify!
2322
24At Spotify, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow, and in the future. To do this we need to understand your listening habits so we can deliver an exceptional and personalized service specifically for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.
23At Spotify, we want to give you the best possible experience to ensure that you enjoy our service. To do this we need to understand your streaming habits so we can deliver an exceptional and personalized service specifically for you. Your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.
2524
2625That is our objective, and this Privacy Policy ("Policy") will explain exactly what we mean in further detail below.
2726
2827## 2\. About this Policy
2928
30This Policy sets out the essential details relating to your personal data relationship with Spotify. The Policy applies to all Spotify services and any associated services (referred to as the 'Spotify Service'). The terms governing your use of the Spotify Service are defined in our [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/) (the "Terms and Conditions of Use").
29This Policy sets out the essential details relating to your personal data relationship with Spotify USA Inc. The Policy applies to all Spotify services and any associated services (referred to as the 'Spotify Service'). The terms governing your use of the Spotify Service are defined in our [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/) (the "Terms and Conditions of Use").
3130
32From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
31From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
3332
3433The aim of this Policy is to:
3534
3635> 1. Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
3736> 2. Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Spotify Service; and
3837> 3. Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
3938
40We hope this helps you to understand our privacy commitments to you. For further clarification of the terms used in this Policy please visit our [Privacy Center](https://www.spotify.com/privacy/plain) on spotify.com. For information on how to contact us if you ever have any questions or concerns, please see the ['How to Contact Us' Section 14]() below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Spotify Service.
39We hope this helps you to understand our privacy commitments to you. For further clarification of the terms used in this Policy please visit our [Privacy Center](https://www.spotify.com/privacy/plain) on spotify.com. For information on how to contact us if you ever have any questions or concerns, please see [Section 13 'How to contact us']() below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Spotify Service.
4140
4241## 3\. Your rights and your preferences: Giving you choice and control
4342
44You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls in our Privacy Center and Privacy Settings to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
43The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
4544
46- Right of Access - the right to be informed of and request access to the personal data we process about you;
47- Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
48- Right to Erasure - the right to request that we delete your personal data;
49- Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
50- Right to Object -
51 - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
52 - the right to object to your personal data being processed for direct marketing purposes;
53- Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
54- Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
45> - Right of access - the right to be informed of, and request access to, the personal data we process about you;
46> - Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
47> - Right to erasure - the right to request that we delete your personal data;
48> - Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
49> - Right to object -
50>
51> - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
52> - the right to object to your personal data being processed for direct marketing purposes;
53>
54> - Right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
55> - Right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
5556
56In order to enable you to exercise these rights with ease and to record your preferences in relation to how Spotify uses your personal data, we provide you with access to the following settings via your Account Settings page:
57In order to enable you to learn more about these rights, exercise these rights with ease, and record your preferences in relation to how Spotify uses your personal data, we provide the following resources:
5758
58- **_Privacy Settings_** - allows you to control some of the categories of personal data we process about you, enables you to access your personal data via a 'Download my Data' button, and includes a link to the [Privacy Center](https://www.spotify.com/privacy/plain) on spotify.com where you can find out more information about how Spotify uses your personal data and what your rights are; and,
59- **_Notification Settings_** - allows you to choose which communications you receive from Spotify, manage your publicly available personal data, and set your sharing preferences.
59> - **Privacy Settings** (accessed via your account page) - allows you to exercise choices about the processing of certain personal data, and an automated 'Download your data' function to download basic account and usage information.
60>
61> - [Privacy Center](https://www.spotify.com/privacy/plain) - provides a convenient central location where you can find more information about how Spotify uses your personal data, your rights in relation to your personal data, and how to exercise those rights.
62>
63> - **Notification Settings** (accessed via your account page) - allows you to choose which marketing communications you receive from Spotify. You may toggle these settings to opt in or out of receiving different types of email and push notifications. Please note that email marketing messages from Spotify include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you). Clicking on the link in an email will opt you out of further messages of that category (e.g. Artist Updates). You can use the Notification Settings page to exercise choices about all categories of email and push marketing communication.
64>
65> - [Cookies Policy](https://www.spotify.com/us/legal/cookies-policy/) - provides more information on how we use cookies, including for interest-based advertising. You will also find information about how you can manage your cookie preferences and opt-out of certain types of tracking; and
66>
67> - **Customer Support resources** - We have several pages on our customer support site which provide further guidance about data protection questions. A key source of information is the Data Rights and Privacy Settings article which includes answers to "frequently asked questions" about personal data processing in the Spotify Service.
68>
6069
61The Privacy Center puts you in control of how Spotify processes your personal data. It provides you with information about what happens if you adjust your settings on your Account Settings page and how to opt out of receiving certain messages from Spotify. If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection ("opt-out") at no cost. The electronic marketing messages you receive from Spotify (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).
70If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the 'Contact Us' form on the [Privacy Center](https://www.spotify.com/privacy/plain). If you have concerns around our processing of your personal data, we hope you will continue to work with us to resolve them. However, you can also contact and have the right to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen) or your local Data Protection Authority.
6271
63You can find out more about the GDPR rights described above and the controls we provide to all Spotify users with respect to these rights in the 'Your Rights' section contained in the Privacy Center. If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the 'Contact Us' form on the Privacy Center. We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen) or your local Data Protection Authority.
72If you are a resident of the state of California, USA, please see our supplemental policy ["Additional California Privacy Disclosures"](https://www.spotify.com/us/legal/california-privacy-disclosure/) which discusses additional privacy rights you may have under applicable law regarding the processing of your personal data.
6473
65## 4\. How do we collect your personal data?
74## 4\. Personal data we collect from you
6675
67We collect your personal data in the following ways:
76We have set out in the tables below the categories of personal data we collect and use about you and how we collect it:
6877
69> 1. **When you sign up for the Spotify Service** - when you sign up to the Spotify Service, we collect certain personal data so you can use the Spotify Service such as your email address, birth date, gender, and country.
70> 2. **Through your use of the Spotify Service** - when you use the Spotify Service, we collect personal data about your use of the Spotify Service, such as what songs you have played and what playlists you have created.
71> 3. **Personal data collected that enables us to provide you with additional features/functionality** - from time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. As described further below (see Voluntary Music Data), we will not collect photos, precise mobile device location, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.
72> 4. **From third parties** - we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with the Spotify Service (please see ['Sharing your personal data' Section 7]() below). We will use this personal data either where you have provided your consent to the third party or to Spotify to that data sharing taking place or where Spotify has a legitimate interest to use the personal data in order to provide you with the Spotify Service.
78**_The table below describes personal data collected when you sign up for the Spotify Service:_**
7379
74We use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Spotify Service, and developing new features and functionality within the Spotify Service.
75
76## 5.What personal data do we collect from you?
77
78We have set out in the tables below the categories of personal data we collect and use about you:
79
80**_Personal data collected when you sign up for the Spotify Service_**
81
8280| Categories of personal data | Description of category |
8381| --- | --- |
84| **Account Registration Data** | This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Spotify Service. This includes your email address, birth date, gender, postal code, and country.
85Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized.
82| **User Data** | This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Spotify Service. Depending on the type of Spotify Service plan you sign up for, this may include your username, email address, phone number, birth date, gender, street address, and country.
83Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with additional personal data in order to make your account more personalized.
8684
87The exact personal data we will collect depends on the type of Spotify Service plan you sign up for and whether or not you use a Third Party Service (as defined in the [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/), such as Facebook) to sign up and use the Spotify Service. If you use a Third Party Service to create an account, we will receive personal data via that Third Party Service but only when you have consented to that Third Party Service sharing your personal data with us.
85The exact personal data we will collect depends on the type of Spotify Service plan you sign up for, how you create an account, and whether you use third party services (such as Facebook) to sign up and use the Spotify Service. If you use a third party service to create an account, we will receive personal data via that third party service but only when you have consented to that third party service sharing your personal data with us. Please note that the available plans and sign-up options may differ by country.
8886
8987 |
9088
91**_Personal data collected through your use of the Spotify Service_**
89**_The table below describes personal data collected through your use of the Spotify Service:_**
9290
9391| Categories of personal data | Description of category |
9492| --- | --- |
95| **Spotify Service Usage Data** | This is the personal data that is collected about you when you are using the Spotify Service - this may include:
93| **Usage Data** | This is the personal data that is collected about you when you're accessing and/or using the Spotify Service, including:
9694> - Information about your type of Spotify Service plan.
97> - Information about your interactions with the Spotify Service which includes the date and time of any requests you make, songs you have listened to, playlists you create, video content you've watched, and your interactions with other Spotify users. This also may include details of your use of Third Party Applications and advertising you receive.
98> - User Content (as defined in the [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/)) you post to Spotify including messages you send and/or receive via Spotify and your interactions with the Spotify Customer Service team.
99> - Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Spotify Service, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Spotify application version. Further details about the technical data that is processed by us can be found in our [Cookies Policy](https://www.spotify.com/us/legal/cookies-policy/).
100> - Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Spotify Service to you.
95> - Information about your interactions with the Spotify Service such as your search queries (including the date and time of any requests you make), streaming history, playlists you create, your library, your browsing history, and your interactions with the Spotify Service, content, other Spotify users. This also may include details of your use of third party applications in connection with the Spotify Service.
96> - Inferences drawn about your interests and preferences based on your usage of the Spotify Service.
97> - User Content (as defined in the [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/)) you post to Spotify, such as photos, playlist titles, and interactions with the Spotify Customer Service team. Please note that we will only access your camera or photos from your device if you give us permission to do so, and we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your device's photo library or camera roll.
98> - Certain technical data, which may include:
99>
100> - URL information;
101> - online identifiers including cookie data and IP addresses;
102> - information about the types of devices you are using such as unique device IDs, network connection type (e.g. wifi, 3G, LTE, Bluetooth), provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Spotify application version;
103> - device attributes of devices on your wifi network that are available to connect to the Spotify Service (such as speakers);
104> - your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device, or payment currency), to comply with geographic requirements in our licensing agreements, and deliver personalized content and advertising to you; and
105> - motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Spotify Service to you.
101106
102107 |
108| **Plan Verification Data** | For users of certain plans like the Premium Family Plan and Premium Duo Plan, we may use a third party mapping application (such as Google Maps) and/or your device's location service to help you verify your address. This data is collected for the sole purpose of verifying eligibility for the Premium Family Plan and Premium Duo Plan and is not used for advertising or any other purpose. |
103109
104**_Personal data collected with your permission that enables us to provide you with additional features/functionality_**
110**_The table below describes personal data that you choose to give us that enables us to provide you with additional features/functionality_**
105111
106112| Categories of personal data | Description of category |
107113| --- | --- |
108| **Voluntary Mobile Data** | In addition to the mobile data we collect to provide you with the Spotify Service ([outlined above]()), you also have the option to give us your consent to collect additional personal data from your mobile device to provide you with features/functionality that will enhance your Spotify Service experience.
109We will not access any of the personal data listed below without first obtaining your consent:
110
111> - Your photos - If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll;
112> - Your precise mobile device location - If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Spotify Service. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements;
113> - Your voice data - If you give us permission, this enables us to access the voice commands captured via your device microphone to enable you to interact with the Spotify Service with your voice. Please note you will always have the ability to turn off the microphone feature; and,
114> - Your contacts - If you give us permission to access your contacts, this enables us to access individual contacts stored on your device to help you find friends who use Spotify.
115
116 |
117| **Payment Data** | We may collect such personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/)) or make other purchases through the Spotify Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:
118
114| **Voice Data** | If voice features are available in your market, we collect your voice data with your permission to provide you with additional features and functionalities, such as interacting with the Spotify Service with your voice. For more information see our [Voice Control Policy](https://www.spotify.com/us/legal/voice-controls/). |
115| **Payment and Purchase Data** | We may collect certain personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/)) or make other purchases through the Spotify Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:
119116> - Name;
120117> - Date of birth;
121118> - Credit or debit card type, expiration date, and certain digits of your card number;
122119> - Postal code;
123120> - Mobile phone number; and
124> - Details of your transaction history.
121> - Details of your purchase and payment history.
125122
126If you choose to pay by invoice, we will provide your personal data to our payment processors to enable them to complete a credit check and to send you invoices. |
127| **Contests, Surveys and Sweepstakes Data** | This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion. |
128| **Marketing Data** | This personal data is used to enable Spotify and our partners / service providers to send you marketing communications either:
123 |
124| **Contests, Surveys and Sweepstakes Data** | When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide. |
129125
130> - Via email;
131> - Whilst using the Spotify Service; and/or
132> - Direct from the third party.
126**_The table below describes personal data collected from third party sources_**
133127
134You can find out more about the personal data collected and the controls you have in relation to the marketing communications you receive via the [Privacy Center](https://www.spotify.com/privacy/plain) |
128We collect personal data about you from various third parties. These third party sources vary over time and include the following:
135129
136## 6\. What do we use your personal data for?
130| Categories of third party sources | Description of category |
131| --- | --- |
132| **Authentication partners** | If you register for or log into our services using third party credentials (e.g. Facebook), we will import your information from such third party to help create your account with us. |
133| **Technical service partners** | We work with technical service partners that provide us with certain data, such as mapping IP addresses to non-precise location data (e.g., city, state), to enable us to provide the Spotify Service, content, and features. |
134| **Payment partners** | If you choose to pay for a service or feature by invoice, we may receive data from our payment partners to enable us to send you invoices, process your payment and provide you with what you've purchased. |
135| **Advertisers and other advertising partners** | We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness. |
137136
138When you use or interact with the Spotify Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in [Section 5 'What personal data do we collect from you?']()) used for these purposes:
137## 5\. What we use your personal data for
139138
139When you use or interact with the Spotify Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in [Section 4 'Personal data we collect from you']() used for these purposes:
140
140141| Description of why Spotify processes your personal data ('processing purpose') | Legal Basis for the processing purpose | Categories of personal data used by Spotify for the processing purpose |
141142| --- | --- | --- |
142| To provide, personalize, and improve your experience with the Spotify Service and other services and products provided by Spotify, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of the Spotify Service (including for third party products and services). |
143| To provide and personalize the Spotify Service. |
143144> - Performance of a Contract
144145> - Legitimate Interest
146> - Consent
145147
146148 |
147149
148> - Account Registration Data
149> - Service Usage Data
150> - User Data
151> - Usage Data
152> - Payment and Purchase Data
153> - Plan Verification Data
154> - Voice Data
150155
151156 |
152| To understand how you access and use the Spotify Service to ensure technical functionality of the Spotify Service, develop new products and services, and analyze your use of the Spotify Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Spotify Service. |
157| To understand, diagnose, troubleshoot, and fix issues with the Spotify Service. |
153158
154159> - Performance of a Contract
155160> - Legitimate Interest
156161
157162 |
158163
159> - Account Registration Data
160> - Service Usage Data
164> - User Data
165> - Usage Data
161166
162167 |
163| To communicate with you for Spotify Service-related purposes. |
168| To evaluate and develop new features, technologies, and improvements to the Spotify Service. |
164169
165> - Performance of a Contract
166170> - Legitimate Interest
171> - Consent
167172
168173 |
169174
170> - Account Registration Data
171> - Service Usage Data
175> - User Data
176> - Usage Data
177> - Voice Data
172178
173179 |
174| To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Spotify Service. |
180| For marketing, promotion, and advertising purposes. |
175181
176> - Performance of a Contract
177> - Compliance with legal obligations
178182> - Legitimate Interest
183> - Consent
179184
180185 |
181186
182> - Payment Data
187> - User Data
188> - Usage Data
189> - Voice Data
183190
184191 |
185| To communicate with you, either directly or through one of our partners, for:
192| To comply with legal obligations and law enforcement requests. |
186193
187> - marketing,
188> - research,
189> - participation in contests, surveys and sweepstakes,
190> - promotional purposes,
194> - Compliance with legal obligations
195> - Legitimate interest
191196
192via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your Account Settings page). |
197 |
193198
194> - Consent
195> - Legitimate Interest
199> - User Data
200> - Usage Data
201> - Payment and Purchase Data
202> - Plan Verification Data
203> - Voice Data
204> - Contests, Surveys and Sweepstakes Data
196205
197206 |
207| To fulfill contractual obligations with third parties, for example licensing agreements and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content. |
198208
209> - Legitimate interest
210
211 |
212
213> - User Data
214> - Usage Data
215> - Payment and Purchase Data
216
217 |
218| To establish, exercise, or defend legal claims. |
219
220> - Legitimate interest
221
222 |
223
224> - User Data
225> - Usage Data
226> - Payment and Purchase Data
227> - Plan Verification Data
228> - Voice Data
199229> - Contests, Surveys and Sweepstakes Data
200> - Marketing Data
201230
202231 |
203| To provide you with features, information, advertising, or other content which is based on your specific location. |
232| To conduct business planning, reporting, and forecasting. |
204233
234> - Legitimate interest
235
236 |
237
238> - User Data
239> - Usage Data
240> - Payment and Purchase Data
241
242 |
243| To process your payment. |
244
245> - Performance of a Contract
246> - Compliance with legal obligations
247
248 |
249
250> - User Data
251> - Payment and Purchase Data
252
253 |
254| To detect fraud, including fraudulent payments and fraudulent use of the Spotify Service. |
255
256> - Performance of a Contract
257> - Compliance with legal obligations
258> - Legitimate Interest
259
260 |
261
262> - User Data
263> - Usage Data
264> - Payment and Purchase Data
265> - Plan Verification Data
266
267 |
268| To conduct research, contests, surveys, and sweepstakes. |
269
270> - Performance of a Contract
271> - Legitimate Interest
205272> - Consent
206273
207274 |
208275
209> - Voluntary Mobile Data
276> - User Data
277> - Usage Data
278> - Contests, Surveys and Sweepstakes Data
210279
211280 |
212281
213If you require further information about the balancing test that Spotify has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see [Section 14 'How to contact us']() for further details on how to contact us.
282If you require further information about the balancing test that Spotify has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see [Section 13 'How to contact us']() for further details on how to contact us.
214283
215## 7\. Sharing your personal data
284## 6\. Sharing your personal data
216285
217286We have set out the categories of recipients of the personal data collected or generated through your use of the Spotify Service.
218287
219288**_Publicly available information_**
220289
221290The following personal data will always be publicly available on the Spotify Service: your name and/or username, profile picture, who you follow and who follows you on the Spotify Service, your recently played artists, and your public playlists.
222291
223292**_Personal data you may choose to share_**
224293
225294The following personal data will only be shared with the categories of recipients outlined in the table below if:
226295
227- you choose to make use of a specific Spotify Service feature where sharing of particular personal data is required for the proper use of the Spotify Service feature; or
296> - you choose to make use of a specific Spotify Service feature where sharing of particular personal data is required for the proper use of the Spotify Service feature; or
297> - you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Spotify Service or authorizing Spotify through a presented consent mechanism.
228298
229- you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Spotify Service.
230
231299| Categories of Recipients | Reason for sharing |
232300| --- | --- |
233| **Third Party Applications you connect to your Spotify Account** | If you connect your Spotify account to a Third Party Application, such as, for example, social media, audio, television, or automotive platforms, Spotify may share your Service Usage Data so you can connect to your Spotify account. |
234| **Third Party Applications you use to log into Spotify** | If you log into a Third Party Application using your Spotify account credentials, then that Third Party Application may have access to certain Service Usage Data such as your playlists, saved content and activity.
235You will receive a notification before connecting to the Third Party Application to let you know what personal data will be shared / accessible to that Third Party Application.
301| **Third party applications and devices you connect to your Spotify Account** | If you connect your Spotify account to a third party application and/or device(s), such as, social media, audio, television, or automotive platforms and services, Spotify shares technical data with the operator of that third party application and/or device in order to connect your Spotify account, and/or facilitate playback of the Spotify Service. With respect to certain third parties which may request or require that we share your information with them, your permission will be requested before we provide your information to such third parties. |
302| **Support community** | When you register for a Spotify Support Account on the Spotify Support Community, we will ask you to create a specific Spotify Support Community username. This will be publicly displayed to anyone who accesses the Spotify Support Community along with any questions or comments you post. |
303| **Your Spotify followers** | There may be times when you want us to share information about your use of the Spotify Service with other Spotify users known as 'Your Spotify Followers'. For example, you have the ability to make both private and public playlists. If you share your private playlists with others, please be aware that the recipients of your private playlists can further share those playlists with others. |
304| **Artists and record labels** | You may choose to share personal data (for example, your email address) with artists, record labels, or other partners who may want to directly send you news or promotional offers. You will always have the option to change your mind and withdraw your consent at any time. |
236305
237 |
238| **Support Community** | When you register for a Spotify Support Account on the Spotify Support Community, we will ask you to create a specific Spotify Support Community username. This will be publicly displayed to anyone who accesses the Spotify Support Community along with any questions or comments you post. |
239| **Your Spotify Followers** | There also may be times when you want us to share certain Service Usage Data, specifically information about your use of Spotify, with other Spotify users known as 'Your Spotify Followers'.
306Learn more about how to manage notifications, your publicly available information, and what you share with others in [Section 3 'Your rights and your preferences: Giving you choice and control']() of this Policy and on the [Privacy Center](https://www.spotify.com/privacy/plain).
240307
241For example, when you make playlists, you might want those playlists to be visible to others on the Spotify Service, but you can also make your playlists private at any time.
242
243 |
244| **Artists and Record Labels** | You can ask us to share personal data (like your email address) with artists or record labels, or other partners who may want to directly send you news or promotional offers, but you can also revoke that consent at any time. |
245
246Learn more about how to manage notifications, your publicly available information, and what you share with others in the ['Your rights and your preferences: Giving you choice and control' Section 3]() of this Policy and on the [Privacy Center](https://www.spotify.com/privacy/plain).
247
248308**_Information we may share_**
249309
250310| Categories of Recipients | Reason for sharing |
251311| --- | --- |
252| **Service Providers and Others** | We use technical service providers which may operate the technical infrastructure that we need to provide the Spotify Service, in particular providers which host, store, manage, and maintain the Spotify application, its content and the data we process.
253We use technical service providers to help us communicate with you, as described in [Section 6]() of this Policy.
254We use marketing and advertising partners to show you more tailored content, or to help us understand your use of the Spotify Service, to provide you with a better service. We also may share personal data with certain marketing and advertising partners to send you promotional communications about Spotify. |
255| **Spotify Partners** | If you access the Spotify Service through an offer that you received or purchased from a third party such as your mobile network operator, we share personal data with that third party about your use of the Spotify Service, such as whether and to what extent you have used the offer, activated a Spotify account, or actively used the Spotify Service.
256Depending on how you sign up for the Spotify Service (e.g. through a third party service or a mobile provider), we share your Spotify username or other Account Registration Data as necessary to enable your account.
257We also may share your personal data in a pseudonymised format with our music industry partners to help them understand how the content they license to us is performing and to enable you to listen to streaming content via the Spotify Service.
258We also share your personal data in a pseudonymised format with marketing partners who help us with promotional efforts and with advertisers that allow us to offer a free service. |
259| **Academic Researchers** | We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format. |
260| **Other Spotify Group Companies** | We will share your personal data with other Spotify Group companies to carry out our daily business operations and to enable us to maintain and provide the Spotify Service to you. |
261| **Law Enforcement and Data Protection Authorities** | We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.
262We also will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party's legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
312| **Service providers** | We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide customer service support, operate the technical infrastructure that we need to provide the Spotify Service, assist in protecting and securing our systems and services, and help market Spotify's own products and services as well as partner products, services, events, and co-branded promotions in which Spotify is involved. |
313| **Payment processors** | We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes. |
314| **Advertising partners** | We work with advertising partners to enable us to customize the advertising content you may receive on the Spotify Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Spotify Service. We and our advertising partners may process certain personal data to help Spotify understand your interests or preferences so that we can deliver advertisements that are more relevant to you. |
315| **Spotify partners** | Depending on how you sign up for the Spotify Service (e.g. through a third party service or a mobile provider), we share your Spotify username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Spotify Service, such as whether and to what extent you have used the offer, activated a Spotify account, or actively used the Spotify Service. We also may share your personal data in a pseudonymised format with our music industry partners to help them understand how the content they license to us is performing and to enable you to listen to streaming content via the Spotify Service. |
316| **Academic researchers** | We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format. |
317| **Other Spotify group companies** | We will share your personal data with other Spotify group companies to carry out our daily business operations and to enable us to maintain and provide the Spotify Service to you. |
318| **Law enforcement and data protection authorities** | We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party's legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data. |
319| **Purchasers of our business** | We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Spotify will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy. |
263320
264 |
265| **Purchasers of our business** | We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Spotify will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different Privacy Policy. |
321## 7\. Data retention and deletion
266322
267## 8\. Data retention and deletion
268
269323We keep your personal data only as long as necessary to provide you with the Spotify Service and for legitimate and essential business purposes, such as maintaining the performance of the Spotify Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Spotify Service. For example, we keep your playlists, song library, and account information.
270324
271If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
325If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
272326
273- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
274- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
275- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
327> - If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
328> - Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
329> - Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
276330
277## 9\. Transfer to other countries
331## 8\. Transfer to other countries
278332
279Spotify shares your personal data globally with other companies in the Spotify Group in order to carry out the activities specified in this Policy. This includes to Spotify Group companies in the following countries: Australia, Austria, Belgium, Brazil, Canada, Denmark, Finland, France, Germany, Hong Kong, Italy, Japan, Luxembourg, Mexico, The Netherlands, Poland, Singapore, Spain, Sweden, Switzerland, Taiwan, Turkey, United Kingdom and the United States of America. Spotify may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.
333Spotify shares your personal data globally with Spotify group companies in order to carry out the activities specified in this Policy. Spotify may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country.
280334
281335Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Spotify shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
282336
283For further details of the security measures we use to protect your personal data, please see the ['Keeping your personal data safe' Section 11]() of this Policy.
337For further details of the security measures we use to protect your personal data, please see [Section 10 'Keeping your personal data safe']() of this Policy.
284338
285## 10\. Links
339## 9\. Links
286340
287341We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties' privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Spotify Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.
288342
289## 11\. Keeping your personal data safe
343## 10\. Keeping your personal data safe
290344
291345We are committed to protecting our users' personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
292346
293Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Spotify Service.
347Your password protects your user account, so we encourage you to use a strong password that is unique to your Spotify account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Spotify Service.
294348
295## 12\. Children
349## 11\. Children
296350
297The Spotify Service is not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law. Please see our [Terms and Conditions of Use](https://www.spotify.com/us/legal/end-user-agreement/) for further details.
351With the exception of Spotify Kids, a separate Spotify application available in certain markets, the Spotify Service is not directed to children under the age of 13 years. The Spotify Service is also not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under the GDPR or other local law.
298352
299353We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the "Age Limit"). If you are under the Age Limit, please do not use the Spotify Service, and do not provide any personal data to us.
300354
301If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Spotify, please contact us using the 'Contact Us' form on the [Privacy Center](https://www.spotify.com/privacy/plain), and you may request exercise of your applicable rights detailed in the ['Your rights and your preferences: Giving you choice and control' Section 3]() of this Policy.
355If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Spotify, please contact us using the 'Contact Us' form on the [Privacy Center](https://www.spotify.com/privacy/plain), and you may request exercise of your applicable rights detailed in [Section 3 'Your rights and your preferences: Giving you choice and control']() of this Policy.
302356
303357If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Spotify account for that child.
304358
305## 13\. Changes to this Privacy Policy
359## 12\. Changes to this Policy
306360
307361We may occasionally make changes to this Policy.
308362
309When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Spotify Service or by sending you an email. We may notify you in advance.
363When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Spotify Service or by sending you an email and/or a device notification. We may notify you in advance.
310364
311365Please, therefore, make sure you read any such notice carefully.
312366
313367If you want to find out more about this Policy and how Spotify uses your personal data, please visit the [Privacy Center](https://www.spotify.com/privacy/plain) on spotify.com to find out more.
314368
315## 14\. How to contact us
369## 13\. How to contact us
316370
317Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by using the 'Contact Us' form on the [Privacy Center](https://www.spotify.com/privacy/plain) or by writing to us at the following address:
371Thank you for reading our Policy. If you have any questions about this Policy, please contact our Data Protection Officer by using the 'Contact Us' form on the [Privacy Center](https://www.spotify.com/privacy/plain), emailing [privacy@spotify.com](mailto:privacy@spotify.com), or by writing to us at the following address:
318372
319373Spotify USA Inc.
32045 W 18th Street, Floor 7
321New York, NY 10011
374150 Greenwich Street, Floor 62
375New York, NY 10007
322376USA
323377
324378We hope you enjoy Spotify!
325© Spotify USA Inc.
379
380© Spotify AB.