Privacy Policy

DATED 2021-09-01 · VERSION 20211001_rev01 · COMPARED WITH 20210301_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20210301_rev01 to 20211001_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+Your Privacy is important. As of today (1 September 2021), we've updated the language in our Privacy Policy to improve readability so it's easier to understand.
 ## [Spotify Privacy Policy]()
+Effective as of 2020-01-01
+Effective as of 1 September 2021
+[Introduction]()
+[About this Policy]()
+[Your rights and your preferences: Giving you choice and control]()
+[Personal data we collect from you]()
+[What we use your personal data for]()
+[Sharing your personal data]()
+[Data retention and deletion]()
+[Transfer to other countries]()
+[Links]()
+[Keeping your personal data safe]()
+[Children]()
+[Changes to this Policy]()
+[How to contact us]()
+. [About this Policy]()
+. [Your personal data rights and controls]()
+. [Personal data we collect about you]()
+. [Our purpose for using your personal data]()
+. [Sharing your personal data]()
+. [Data retention and deletion]()
+. [Transfer to other countries]()
+. [Keeping your personal data safe]()
+. [Children]()
+. [Changes to this Policy]()
+. [How to contact us]()
+## [1\. Introduction]()
+## [1\. About this Policy]()
+Thanks for choosing Spotify!
+This Policy describes how we process your personal data at Spotify USA Inc.
+At 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.
+It applies to your use of:
+That is our objective, and this Privacy Policy ("Policy") will explain exactly what we mean in further detail below.
+- all Spotify streaming services as a user. This includes use of these services under our free or paid options (each a "Service Option"); and
+- other Spotify services which include a link to this Privacy Policy (e.g. Spotify websites, Customer Support and the Community Site).
+## [2\. About this Policy]()
+From now on, we'll collectively call these the "**Spotify Service**".
+This 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/legal/end-user-agreement) (the "Terms and Conditions of Use").
+From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.
+From 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.
+**This Policy is _not..._**
+The aim of this Policy is to:
+- the Spotify [Terms of Use](https://www.spotify.com/legal/end-user-agreement/). That's a separate document, outlining the legal contract between you and Spotify for using the Spotify Service. It also describes the rules of Spotify and your user rights.
+- about your use of other Spotify services which have their own dedicated privacy policy, such as Anchor, Soundtrap, Megaphone and Greenroom.
+. 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;
+. 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
+. Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
+We have included further information about rights and disclosures as required under the California Consumer Privacy Act (CCPA) in our [California Privacy Disclosures](http://spotify.com/us/legal/California-privacy-disclosure) supplement.
+We 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/us/privacy)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.
+## [2\. Your personal data rights and controls]()
+## [3\. Your rights and your preferences: Giving you choice and control]()
+Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.
+The 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:
+See your rights and their descriptions in this table.
+- Right of access - the right to be informed of, and request access to, the personal data we process about you;
+- Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
+- Right to erasure - the right to request that we delete your personal data;
+- Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
+- Right to object -
+- - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
+    - the right to object to your personal data being processed for direct marketing purposes;
+- 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
+- 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.
+|
+ | **It's your right to...** |
+| --- | --- |
+| Access | Be informed of the personal data we process about you and to request access to it |
+| Rectification | Request that we amend or update your personal data where it's inaccurate or incomplete |
+| Erasure | Request that we delete certain of your personal data |
+| Restriction | Request that we temporarily or permanently stop processing all or some of your personal data |
+| Object | Object to us processing your personal data at any time, on grounds relating to your particular situation
+Object to your personal data being processed for direct marketing purposes |
+| Data portability | 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 |
+| Not be subject to automated decision-making | Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect |
+In 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:
+**How to exercise your rights with Spotify**
+- **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.
+- [Privacy Center](https://www.spotify.com/us/privacy) - 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.
+- **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.
+- [Cookies Policy](https://www.spotify.com/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
+- **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.
+**Access:** To request a copy of your personal data from Spotify, visit your account [Privacy Settings](https://www.spotify.com/account/privacy/). There you can automatically download much of your personal data and find out how to request more information.
+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](https://www.spotify.com/us/privacy). 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 (Integritetsskyddsmyndigheten) or your local Data Protection Authority.
+**Rectification:** You can edit your User Data under "Edit profile" in your account.
+Additional privacy rights under the California Consumer Privacy Act (CCPA) can be found in our supplemental policy ["Additional California Privacy Disclosures"](https://www.spotify.com/us/legal/california-privacy-disclosure/), which contains supplemental disclosures relating to the processing of your personal data.
+**Erasure:**
+## [4\. Personal data we collect from you]()
+- You can remove audio content from your profile by selecting the relevant content and choosing to remove it. For example, you can remove playlists from your profile, or remove a track from your playlist.
+- To request erasure of your other personal data from Spotify (e.g. your User Data, Usage Data and other data listed in Section 3 'Personal data we collect about you' below), see our [support page](https://support.spotify.com/article/close-account/).
+We have set out in the tables below the categories of personal data we collect and use about you and how we collect it:
+**Your other rights:** You can contact Spotify directly to exercise your rights at any time (see Section 11 'How to contact us').
+**_The table below describes personal data collected when you sign up for the Spotify Service:_**
+In addition, here are more privacy resources and controls:
+| Categories of personal data | Description of category |
+| --- | --- |
+| **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.
+Some 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.
+- [Privacy Center](https://www.spotify.com/privacy/) - more information about how Spotify uses your personal data, your rights, and how to use those rights.
+- [Privacy Settings](https://www.spotify.com/account/privacy/) - control the processing of certain personal data, including Tailored Ads.
+- [Notification Settings](https://support.spotify.com/article/notification-settings/) - learn how to set which marketing communications you get from Spotify.
+- Settings (Desktop and Mobile) - control certain aspects of the Spotify Service such as "Social" and "Explicit Content".
+- [Cookies Policy](https://www.spotify.com/legal/cookies-policy/) - information on how we use cookies and how to manage your cookie preferences. Cookies are files saved on your phone, tablet or computer when you visit a website.
+The 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.
+You also have the right to contact the [Swedish Authority for Privacy Protection](https://www.imy.se/) or your local data protection authority about any questions or concerns.
+ |
+## [3\. Personal data we collect about you]()
+**_The table below describes personal data collected through your use of the Spotify Service:_**
+These tables set out the categories of personal data we collect and use.
+| Categories of personal data | Description of category |
+| --- | --- |
+| **Usage Data** | This is the personal data that is collected about you when you're accessing and/or using the Spotify Service, including:
+- Information about your type of Spotify Service plan.
+- 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.
+- Inferences drawn about your interests and preferences based on your usage of the Spotify Service.
+- User Content (as defined in the [Terms and Conditions of Use](https://www.spotify.com/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.
+- Certain technical data, which may include:
+-
+    - URL information;
+    - online identifiers including cookie data and IP addresses;
+    - 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;
+    - device attributes of devices on your wifi network that are available to connect to the Spotify Service (such as speakers);
+    - 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
+    - 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.
+| **Collected when you sign up for the Spotify Service** **or when you update your account** |
+| --- |
+| **Category** | **Description** |
+| User Data | Personal data that we need to create your Spotify account and enables you to use the Spotify Service.
+The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in. This may include your:
+- profile name
+- email address
+- phone number
+- date of birth
+- gender
+- street address
+- country
+We receive some of this data from you e.g. from the sign up form or account page.
+We also collect some of this data from your device e.g. country. For more information about how we collect country, see "Your general (non-precise) location". |
+| Street Address Data | We may ask for your street address for the following reasons:
+- to check eligibility for a Service Option
+- for tax administration
+- to deliver physical goods or gifts requested by you
+In some cases, we may use a third party mapping application (such as Google Maps) to help you verify your address. |
+| **Collected through your use of the Spotify Service** |
+| --- |
+| **Categories** | **Description** |
+| Usage Data
+ | Personal data collected about you when you're accessing and/or using the Spotify Service.
+There are a few types of information this includes, detailed in the following sections.
+**Information about how you use Spotify**
+Examples include:
+- Information about your Spotify Service Option.
+- Your actions with the Spotify Service (including date and time), such as:
+    - search queries
+    - streaming history
+    - playlists you create
+    - your library
+    - browsing history
+    - account settings
+    - interactions with other Spotify users
+    - your use of third party services, devices and applications in connection with the Spotify Service
+- Inferences (i.e., our understanding) of your interests and preferences based on your usage of the Spotify Service.
+- Content you post to any part of the Spotify Service, such as images, text, playlist titles, communications, and other types of content.
+**Your technical data**Examples include:
+- URL information
+- Online identifiers such as [cookie data](https://www.spotify.com/legal/cookies-policy/) and IP addresses
+- Information about the devices you use such as:
+    - device IDs
+    - network connection type (e.g. wifi, 4G, LTE, Bluetooth)
+    - provider
+    - network and device performance
+    - browser type
+    - language
+    - information enabling digital rights management
+    - operating system
+    - Spotify application version
+- Information (such as the device name, device identifiers, brand and version) which enables us to discover and connect with third party devices and applications such as those listed below:
+    - devices on your wifi network (such as speakers) which can connect to the Spotify Service
+    - devices made available by your operating system when connecting via Bluetooth, plugin, and installation
+    - Spotify partner applications to determine whether the application is installed on your device
+**Your general (non-precise) location**
+This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency).
+We need this to meet geographic requirements in our agreements with the owners of content on the Spotify Service, and to deliver content and advertising that's relevant to you.
+**Your device sensor data**
+Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) if needed to provide features of the Spotify Service that require this data.
+ |
+| **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. |
+**_The table below describes personal data that you choose to give us that enables us to provide you with additional features/functionality_**
+| **Additional data you may choose to give us**
+ |
+| --- |
+| **Categories** | **Description** |
+| Voice Data
+ | If voice features are available in your market and only where you've given permission, we collect voice data (audio clips of your voice).
+This makes it possible for us to provide and improve Spotify's voice features.
+For more information see our [Voice Control Policy](https://www.spotify.com/us/legal/voice-controls/). |
+| Payment and Purchase Data | If you make any purchases from Spotify (including a paid Service Option) or sign up for a trial, we will need to process your payment data.
+The exact personal data collected will vary depending on the payment method, but will include information such as:
+- name
+- date of birth
+- credit or debit card type, expiration date, and certain digits of your card numberNote: For security, we never store your full card number
+- ZIP/postal code
+- mobile phone number
+- details of your purchase and payment history
+| Categories of personal data | Description of category |
+| --- | --- |
+| **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/legal/voice-controls/). |
+| **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/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:
+- Name;
+- Date of birth;
+- Credit or debit card type, expiration date, and certain digits of your card number;
+- Postal code;
+- Mobile phone number; and
+- Details of your purchase and payment history.
+ |
+| Contests, Surveys, and Sweepstakes Data | When you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide. |
+| **Collected from other ('third party') sources** |
+| --- |
+| **Categories of third parties** | **Description** |
+| Authentication partners | If you register for or log into our services using another service, we'll receive your information from them to help create your account with us. |
+| Third party applications, services and devices you connect to your Spotify account | If you connect your Spotify account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible.
+These third party apps, services or devices may include:
+- social media
+- devices including:
+    - audio (e.g. speakers and headphones)
+    - smart watches
+    - televisions
+    - mobile phones and tablets
+    - automotive (e.g. cars)
+    - games consoles
+- services or platforms such as voice assistants
+We'll ask your permission before we collect your information from certain third parties. |
+| Technical service partners | We work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state).
+This makes it possible for Spotify to provide the Spotify Service, content, and features. |
+| Payment partners | If you choose to pay Spotify by invoice, we may get data from our payment partners.
+This allows us to:
+- send you invoices
+- process your payment
+- give you what you've purchased
+ |
+| **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. |
+| Advertising and marketing partners | We may get data about you from certain advertising or marketing partners.
+This may include:
+**_The table below describes personal data collected from third party sources_**
+- cookie id
+- mobile device id
+- email address
+- inferences (i.e., our understanding) of your interests and preferences
+We collect personal data about you from various third parties. These third party sources vary over time and include the following:
+This allows us to deliver more relevant ads and marketing. |
+| Categories of third party sources | Description of category |
+| --- | --- |
+| **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. |
+| **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. |
+| **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. |
+| **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. |
+## [4\. Our purpose for using your personal data]()
+## [5\. What we use your personal data for]()
+The table below sets out:
+When 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:
+- our purpose for processing your personal data
+- our legal justifications (each called a "legal basis") under data protection law, for each purpose
+- categories of personal data which we use for each purpose (see more about these categories in Section 3 'Personal data we collect about you')
+| 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 |
+Here is a general explanation of each "legal basis" to help you understand the table:
+- **Performance of a Contract:** When it's necessary for Spotify (or a third party) to process your personal data to:
+    - comply with obligations under a contract with you, e.g. Spotify's obligations under the Terms of Use to provide the Spotify Service to you
+    - or verify information before a new contract with you begins.
+- **Legitimate Interest:** When Spotify (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Spotify users. For example, using your Usage Data to improve the Spotify Service for all users. Contact us if you want to understand a specific justification.
+- **Consent:** When Spotify asks you to actively indicate your agreement to Spotify's use of your personal data for a certain purpose(s).
+- **Compliance with Legal Obligations:** When Spotify must process your personal data to comply with a law.
+| **Purpose for processing your data** | **Legal basis that permits the purpose** | **Categories of personal data used for the purpose**
+ |
 | --- | --- | --- |
+| To provide and personalize the Spotify Service. |
+| To provide the personalized Spotify Service. |
 - Performance of a Contract
 - Legitimate Interest
 - Consent
+ |
 - User Data
 - Usage Data
 - Payment and Purchase Data
+- Plan Verification Data
+- Street Address Data
 - Voice Data
+ |
 | To understand, diagnose, troubleshoot, and fix issues with the Spotify Service. |
 - Performance of a Contract
 - Consent
+ |
 - User Data
 - Usage Data
+- Voice Data
+- Contests, Surveys and Sweepstakes Data
+ |
 | To comply with legal obligations and law enforcement requests. |
 - Compliance with legal obligations
 - Legitimate interest
+ |
 - User Data
 - Usage Data
 - Payment and Purchase Data
+- Plan Verification Data
+- Street Address Data
 - Voice Data
 - Contests, Surveys and Sweepstakes Data
+ |
+| 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. |
+| To:
+- fulfill contractual obligations with third parties, for example our agreements with owners of content on the Spotify Service, and
+- take appropriate action with reports of intellectual property infringement and inappropriate content.
+ |
 - Legitimate interest
+ |
 - User Data
 - Usage Data
+ |
 - User Data
 - Usage Data
 - Payment and Purchase Data
+- Plan Verification Data
+- Voice Data
+- Street Address Data
 - Contests, Surveys and Sweepstakes Data
+ |
 | To conduct business planning, reporting, and forecasting. |
+- Legitimate interest
+- Legitimate Interest
+ |
 - User Data
 - Usage Data
 - Payment and Purchase Data
+ |
 - User Data
 - Payment and Purchase Data
+ |
+| To detect fraud, including fraudulent payments and fraudulent use of the Spotify Service. |
+| To detect and prevent fraud, including fraudulent payments and fraudulent use of the Spotify Service. |
 - Performance of a Contract
 - Compliance with legal obligations
 - Legitimate Interest
+ |
 - User Data
 - Usage Data
 - Payment and Purchase Data
+- Plan Verification Data
+- Street Address Data
+ |
 | To conduct research, contests, surveys, and sweepstakes. |
 - Performance of a Contract
 - Legitimate Interest
 - User Data
 - Usage Data
 - Contests, Surveys and Sweepstakes Data
+ |
+If 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.
+## [5\. Sharing your personal data]()
+## [6\. Sharing your personal data]()
+This section sets out the categories of recipients of the personal data collected or generated through your use of the Spotify Service.
+We have set out the categories of recipients of the personal data collected or generated through your use of the Spotify Service.
+**Publicly available information**
+**_Publicly available information_**
+The following personal data will always be publicly available on the Spotify Service:
+The 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.
+- Your profile name
+- Your profile photo
+- Your public playlists
+- Who you follow on the Spotify Service
+- Who follows you on the Spotify Service (you can remove followers)
+**_Personal data you may choose to share_**
+**Personal data you may choose to share**
+The following personal data will only be shared with the categories of recipients outlined in the table below if:
+We will only share the following personal data with those outlined in the table below:
+- 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
+- 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.
+- where sharing of particular personal data is needed for the use of a Spotify Service feature, or a third party application, service or device, which you have chosen to use; or
+- if you otherwise grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Spotify Service or by giving your consent
+| Categories of Recipients | Reason for sharing |
+| **Categories of recipient** | **Reason for sharing** |
 | --- | --- |
+| **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. |
+| **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. |
+| **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. |
+| **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. |
+| Third party applications, services and devices you connect to your Spotify Account | To connect your Spotify account, and/or allow you to use the Spotify Service in connection with third party applications, services or devices.
+Examples of such third party applications, services and devices include: social media applications, speaker devices, televisions, automotive platforms, or voice assistants, which interact with the Spotify Service.
+You can see and remove many third party connections under "Apps" in your account. |
+| Support community | To enable you to use the Spotify Support Community service.
+When you register for an account on the Spotify Support Community, we'll ask you to create a specific profile name. This will be publicly displayed to anyone who uses the Spotify Support Community. We'll also display any questions or comments you post. |
+| Other Spotify users | To share information about your use of the Spotify Service with other Spotify users, including your 'Spotify Followers'.
+For example, under "Social" settings you can choose whether to share your recently played artists and your playlists on your profile. |
+| Artists and record labels | To receive news or promotional offers directly from artists, record labels or other partners.
+You may choose to share personal data (for example, your email address) for this purpose. You'll always have the option to change your mind and withdraw your consent at any time. |
+Learn 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/us/privacy).
+**Information we may share**
+**_Information we may share_**
+See this table for details of who we share to and why.
+| Categories of Recipients | Reason for sharing |
+| **Categories of recipients** | **Reason for sharing** |
 | --- | --- |
+| **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. |
+| **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. |
+| **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. |
+| **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. |
+| **Academic researchers** | We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format. |
+| **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. |
+| **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. |
+| **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. |
+| Service providers | So they can provide their services to Spotify.
+These service providers may include those we hire to:
+- give customer support
+- operate the technical infrastructure we need to provide the Spotify Service
+- assist in protecting and securing our systems and services (e.g. Google's reCAPTCHA)
+- help market Spotify's (and our partners') products, services, events and promotions
+## [7\. Data retention and deletion]()
+ |
+| Payment processors | So they can process your payments, and for anti-fraud purposes. |
+| Advertising partners | So our ad partners can help us deliver more relevant advertising to you on the Spotify Service.
+For example, our ad partners help us facilitate tailored advertising:
+We 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.
+- This is when we use third party information to tailor ads to be more relevant to you (also known as interest based advertising).
+- An example of a tailored ad is when an ad partner has information suggesting you like cars, which could enable us to show you ads about cars.
+- You can control tailored advertising in your [account privacy settings](https://www.spotify.com/us/account/privacy/) under "Tailored Ads".
+- If you are "opted out" of Tailored Ads, you may still get advertising on ad-supported services (such as podcasts or the Free Service Option) based on your registration information and ads based on the content you are streaming on our Services. For example, if you are streaming a cooking podcast, you may hear an ad for a food processor or if you are streaming a workout playlist, you may hear an ad for sports clothing.
+If 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:
+ |
+| Marketing Partners | To promote Spotify with our partners. We share some personal data with these partners where necessary to:
+- 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;
+- 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,
+- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
+- enable you to participate in Spotify promotions, including trials or other bundled offers
+- to promote Spotify in media and advertising published on other online services
+- help us and our partners to measure the effectiveness of Spotify promotions
+## [8\. Transfer to other countries]()
+Examples of partners include:
+Spotify 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.
+- marketing or sponsorship partners
+- websites and mobile apps who sell us advertising space on their services
+- device, app and mobile partners who also offer Spotify promotions
+Personal 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.
+Our partners may also combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you. |
+| Other partner sharing | We may share personal data with partners to help us understand and improve the performance of our products and partnerships.
+You can see and remove many partner connections under "Apps" in your account. |
+| Academic researchers | For activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you. |
+| Other Spotify group companies | Where we have offices, to carry out our daily business operations and so we can maintain and provide the Spotify Service to you.
+ |
+| Law enforcement and other authorities | When we believe in good faith it's necessary for us to do so, for example:
+For 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.
+- to comply with a legal obligation
+- to respond to a valid legal process (such as a search warrant, court order, or subpoena)
+- for our own or a third party's justifiable interest, relating to:
+    - national security
+    - law enforcement
+    - litigation (a court case)
+    - criminal investigation
+    - protecting someone's safety
+    - preventing death or imminent bodily harm.
+## [9\. Links]()
+ |
+| Purchasers of our business | Where we sell or negotiate to sell our business to a buyer or possible buyer.
+In this situation, Spotify will continue to ensure your personal data is kept confidential. We'll give you notice before your personal data is transferred to the buyer or a different privacy policy starts to apply. |
+We 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.
+## [6\. Data retention and deletion]()
+## [10\. Keeping your personal data safe]()
+**Retention**
+We 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.
+We keep your personal data only as long as necessary to provide you with the Spotify Service and for Spotify's legitimate and essential business purposes, such as:
+Your 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.
+- maintaining the performance of the Spotify Service
+- making data-driven business decisions about new features and offerings
+- complying with our legal obligations
+- resolving disputes
+## [11\. Children]()
+**Deletion**
+With 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.
+If you close or request that we close your account, we'll delete or anonymise your personal data so it no longer identifies you, unless we're required to keep something or we still need to use it for a legally justifiable reason.
+We 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.
+Here are some examples of situations where we're legally allowed or required to keep some of your personal data:
+If 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/us/privacy), 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.
+- if there's an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute
+- for our legal, tax, audit and accounting obligations
+- for our legitimate business interests such as fraud prevention or to maintain security.
+If 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.
+## [7\. Transfer to other countries]()
+## [12\. Changes to this Policy]()
+When carrying out the activities described in this Policy, Spotify shares your personal data internationally with Spotify group companies, subcontractors and partners. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.
+We may occasionally make changes to this Policy.
+Whenever we transfer personal data internationally, we use tools to:
+When 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.
+- make sure the data transfer complies with applicable law
+- help to give your data the same level of protection as it has in the EU
+Please, therefore, make sure you read any such notice carefully.
+We do this using a variety of protections, as appropriate for each data transfer. For example, we use:
+If 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/us/privacy) on spotify.com to find out more.
+- [Standard Contractual Clauses](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/) (or an alternative legal tool) to require the third party to protect your data and to provide you with EU-level rights and protections
+- technical protections, such as encryption and pseudonymisation
+- policies and processes to challenge disproportionate or unlawful government authority requests
+## [13\. How to contact us]()
+You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.
+Thank 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/us/privacy), emailing [privacy@spotify.com](mailto:privacy@spotify.com), or by writing to us at the following address:
+## [8\. Keeping your personal data safe]()
+Spotify USA Inc.
+Greenwich Street, Floor 62
+New York, NY 10007
+USA
+We're committed to protecting our users' personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.
+We hope you enjoy Spotify!
+We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
+To protect your user account, 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
+- log out once you have finished using the Spotify Service on a shared device
+- read more detail on [protecting your account](https://support.spotify.com/article/protect-your-account/)
+You can log out of Spotify in multiple places at once by using the "Sign out everywhere" function on [your account page](http://www.spotify.com/account).
+If other individuals have access to your Spotify account (for example if you've given them permission to use your account on a shared device), then they can access personal data, controls and the Spotify Service available in your account.
+It's your responsibility to only provide individuals with permission to use your account where you're comfortable sharing this personal data with them. Anyone else's use of your Spotify account may impact your personalised recommendations and be included in your data download.
+## [9\. Children]()
+Note: This Policy doesn't apply to Spotify Kids, unless the [Spotify Kids Privacy Policy](https://www.spotify.com/legal/kids-privacy-policy/) says so. Spotify Kids is a separate Spotify application.
+The Spotify Service has a minimum "Age Limit" in each country. The Spotify Service is not directed to children whose age:
+- is under the age of 13 years
+- or, makes it illegal to process their personal data
+- or, requires parental consent to process their personal data
+We do not knowingly collect personal data from children under the applicable Age Limit. If you're under the Age Limit, please do not use the Spotify Service, and do not provide any personal data to us. Instead, we recommend using a [Spotify Kids](http://www.spotify.com/kids) account.
+If you're a parent of a child under the Age Limit and become aware that your child has provided personal data to Spotify, please contact us.
+If we learn that we've collected the personal data of a child under the applicable Age Limit, we'll take reasonable steps to delete the personal data. This may require us to delete the Spotify account for that child.
+When using a shared device on the main Spotify Service, you should be cautious about playing or recommending any content to individuals under 18 years old which could be inappropriate for them.
+## [10\. Changes to this Policy]()
+We may occasionally make changes to this Policy.
+When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Spotify Service or send you an email or device notification.
+## [11\. How to contact us]()
+For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:
+- Use our [privacy contact form](https://support.spotify.com/contact-spotify-privacy/)
+- Email [privacy@spotify.com](mailto:privacy@spotify.com)
+- Write to us at: Spotify USA Inc., 150 Greenwich Street, Floor 62, New York, NY 10007, USA
+You can also visit our [Privacy Center](https://www.spotify.com/privacy/) for more clarification of this Policy.
 © Spotify USA Inc.