Privacy Policy

DATED 2022-06-08 · VERSION 20220701_rev01 · COMPARED WITH 20220301_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20220301_rev01 to 20220701_rev01

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

+## [Spotify Privacy Policy]()
+Your privacy is important. As of 8 June 2022, we've updated our Privacy Policy to improve clarity and reflect some exciting new features.
+Effective as of 1 September 2021
+## [**Spotify Privacy Policy**]()
+. [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]()
+Effective as of 8 June 2022
+To help you understand this Policy, our [privacy videos](https://www.spotify.com/privacy) bring privacy at Spotify to life.
+[1 About this Policy]()
+## [1\. About this Policy]()
+[2 Your personal data rights and controls]()
+This Policy describes how we process your personal data at Spotify USA Inc.
+[3 Personal data we collect about you]()
+[4 Our purpose for using your personal data]()
+[5 Sharing your personal data]()
+[6 Data retention]()
+[7 Transfer to other countries]()
+[8 Keeping your personal data safe]()
+[9 Children]()
+[10 Changes to this Policy]()
+[11 How to contact us]()
+## **1\. About this Policy**
+This Policy describes how we process your personal data at USA Inc.
 It applies to your use of:
+- 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).
+- all Spotify streaming services as a user. For example this includes:
+    - your use of Spotify on any device
+    - the personalization of your user experience - watch [our personalization explainer video](https://www.spotify.com/privacy) to learn more about this
+    - the infrastructure required to provide our services
+    - connection of your Spotify account with another application
+    - both our free or paid streaming options (each a '**Service Option**')
+- other Spotify services which include a link to this Privacy Policy. These include Spotify websites, Customer Service and the Community Site
+From now on, we'll collectively call these the "**Spotify Service**".
+From now on, we'll collectively call these the '**Spotify Service**'.
 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.
+**This Policy is _not..._**
+**This Policy is _not_...**
+- 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.
+- the Spotify [Terms of Use](https://www.spotify.com/legal/end-user-agreement/), which is a separate document. The Terms of Use outline 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 privacy policy. Other Spotify services include Anchor, Soundtrap, Megaphone and the Spotify Live app
 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.
+## [2\. Your personal data rights and controls]()
+**Other resources and settings**
+Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.
+Key information about your personal data is right here in this Policy. However, you might want to take a look at our other privacy resources and controls:
+See your rights and their descriptions in this table. You can also watch our video about [Your Privacy Controls](https://www.youtube.com/watch).
+- [Privacy Center](https://www.spotify.com/privacy/): A user-friendly hub with summaries of key topics and helpful videos. It includes the 'Your Privacy Controls' video which shows you how to exercise your user rights and make choices about the way we process your data (see [Section 2 'Your personal data rights and controls']() for more on user rights).
+- [Privacy Settings](https://www.spotify.com/account/privacy/): Control the processing of certain personal data, including Tailored Ads.
+- [Notification Settings](https://www.spotify.com/account/notifications/) Set which marketing communications you get from Spotify.
+- Settings (found in the Desktop and Mobile versions of Spotify): Control certain aspects of the Spotify Service such as 'Social' or 'Explicit Content'. On the 'Social' setting, you can:
+    - start a Private session
+    - choose whether to share what you listen to on Spotify with your followers
+    - choose whether to show your recently played artists on your public profile
+On the 'Explicit Content' setting you can control whether explicit-rated content can be played on your Spotify account.
+- [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.
+[Top of page ↑]()
+## **2\. Your personal data rights and controls**
+Privacy laws, including the General Data Protection Regulation ('**GDPR**'), give rights to individuals over their personal data.
+Some rights only apply when Spotify uses a certain 'legal basis' to process your data. We explain each legal basis, and when Spotify uses each one, in [Section 4 'Our purpose for using your personal data']().
+The table below explains:
+- your rights
+- circumstances when they apply (such as the legal basis required)
+- how to use them
+You can also watch our video about [Your Privacy Controls](https://www.spotify.com/privacy).
+|
+ | **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 |
+ | It's your right to... | How? |
+| --- | --- | --- |
+| **Be informed** | **Be informed of the personal data we process about you and how we process it.** | We inform you:
+- through this Privacy Policy
+- through information provided to you as you use the Spotify Service
+- by answering your specific questions and requests when you [contact us]()
+**How to exercise your rights with Spotify**
+ |
+| **Access** | **Request access to the personal data we process about you.**
+ | To request a copy of your personal data from Spotify, either:
+**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.
+- 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 additional information, or
+- [contact us]() to get all information we hold about you at once, without using the automatic download tool first
+**Rectification:** You can edit your User Data under "Edit profile" in your account.
+When you download your data you will receive the information about your data that Spotify has to provide under Article 15 of the GDPR. If you would like more information about how we process your personal data, you can [contact us](). |
+| **Rectification** | **Request that we amend or update your personal data where it's inaccurate or incomplete.** | You can edit your User Data under 'Edit profile' in your account or [by contacting us](). |
+| **Erasure** | **Request that we erase certain of your personal data.**
+For example, you can ask us to erase personal data:
+**Erasure:**
+- that we no longer need for the purpose it was collected for
+- that we process based on the [legal basis]() of consent, and you withdraw your consent
+- when you object (see section 'Object' below) and
+    - you make a justified objection, or
+    - you object to direct marketing
+- 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/).
+There are situations where Spotify is unable to delete your data, for example when:
+**Your other rights:** You can contact Spotify directly to exercise your rights at any time (see Section 11 'How to contact us').
+- it's still necessary to process the data for the purpose we collected it for
+- Spotify's interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud
+- Spotify has a legal obligation to keep the data, or
+- Spotify needs the data to establish, exercise or defend legal claims. For example, if there's an unresolved issue relating to your account
+In addition, here are more privacy resources and controls:
+ | There are several ways you can erase personal data from Spotify:
+- [Privacy Center](https://www.spotify.com/privacy/) - more information about how Spotify uses your personal data, your rights, and how to use those rights, including our video, about [Your Privacy Controls](https://www.youtube.com/watch).
+- [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.
+- 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, follow the steps on our [support page](https://support.spotify.com/article/close-account/). This data includes your User Data, Usage Data and other data listed in [Section 3 'Personal data we collect about you]()'
+- you can also [contact us]() directly to request erasure
+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.
+ |
+| **Restriction** | **Request that we stop processing all or some of your personal data.**
+You can do this if:
+## [3\. Personal data we collect about you]()
+- your personal data is inaccurate
+- our processing is unlawful
+- we do not need your information for a specific purpose, or
+- you object to our processing and we are assessing your objection request. See section 'Object' below
+These tables set out the categories of personal data we collect and use. You can also watch our video about [Personal Data at Spotify](https://www.youtube.com/watch).
+You can request that we stop this processing temporarily or permanently. | You can exercise your right to restriction [by]() [contacting us](). |
+| **Object** | **Object to us processing your personal data.**
+You can do this if:
+| **Collected when you sign up for the Spotify Service** **or when you update your account** |
+- Spotify is processing your personal data on the legal basis of legitimate interests, or
+- Spotify is processing your personal data for direct marketing
+ | To exercise your right to object:
+- you can use controls on Spotify Service to switch off or adjust some features which process your personal data. For example, you can switch off 'Tailored Ads' in your [Privacy Settings](https://www.spotify.com/account/privacy/)
+- where Spotify does not provide a control, [contact us]() to object
+ |
+| **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.**
+You can request us to transmit your data when we are processing your personal data on the legal basis of consent or performance of contract. However Spotify will try to honour any request to the extent possible. | For information about how to exercise the right to portability, please see 'Access' above. |
+| **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.** | Spotify does not carry out this type of automated decision making in the Spotify Service. |
+| **Withdrawal of consent** | **Withdraw your consent to us collecting or using your personal data.**
+You can do this if Spotify is processing your personal data on the [legal basis]() of consent. | To withdraw your consent, you can:
+- adjust the relevant control on Spotify
+- [contact us]()
+ |
+| **Right to lodge a complaint** | **Contact the Swedish Authority for Privacy Protection or your local data protection authority about any questions or concerns.** | You can find the Swedish Authority's details [here](https://www.imy.se/), or go to the website of your local data protection authority. |
+[Top of page ↑]()
+## **3\. Personal data we collect about you**
+These tables set out the categories of personal data we collect and use. You can also watch our video about [Personal Data at Spotify](https://www.spotify.com/privacy).
+| 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:
+| User Data | Personal data that we need to create your Spotify account and that enables you to use the Spotify Service.
+The type of data collected and used depends on the type of Service Option you have. It also depends on 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
+- street address (see further details below)
 - 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:
+We also collect some of this data from your device e.g. country or region. For more information about how we collect and use this data, see 'Your general (non-precise) location' in the Usage Data category. |
+| Street Address Data | We may ask for and process 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
+- to deliver notices which are required by law
+- to deliver support options
+- for billing and tax administration
+- to deliver physical goods or gifts which you have requested
+In some cases, we may use a third party mapping application (such as Google Maps) to help you verify your address. |
+In some cases, we may use a third party application to help you verify your address, such as Google Maps. |
+| **Collected through your use of the Spotify Service** |
+| 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.
+ | Personal data collected and processed about you when you're accessing or using the Spotify Service.
+There are a few types of information this includes, listed 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:
+- 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.
+- inferences (i.e., our understanding) of your interests and preferences based on your usage of the Spotify Service
+- content you provide when participating in Spotify promotions, such as contests or sweepstakes
+- content you post to any part of the Spotify Service. For example: images, audio, text, titles, descriptions, 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:
+- 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:
+- information which enables us to discover and connect with third party devices and applications. Examples of this information are the device name, device identifiers, brand and version. Examples of third party devices and applications are:
     - 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 general location includes country, region or state. We may learn this 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
+- 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. |
+| **Additional data you may choose to give us**
+ |
+| 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:
+ | If voice features are available in your market and where you've chosen to use a voice feature, we collect and process voice data. Voice data means audio recordings of your voice and transcripts of those recordings.
+For more information on how different voice features work, and how you can control and turn them off, see our [Voice Control Policy](https://www.spotify.com/us/legal/voice-controls/).
+ |
+| Payment and Purchase Data | If you make any purchases from Spotify or sign up for a trial, we will need to process your payment data. This includes if you buy a paid Service Option.
+The exact personal data collected and used will vary depending on the payment method. It 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
+- payment method type (e.g. credit or debit card)
+- if using a debit or credit card, the 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
+ |
+| 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. |
+| Survey and Research Data | When you respond to a survey or take part in user research, we collect and use the personal data you provide. |
+| **Collected from other ('third party') sources** |
+| Third party sources that we collect your data from |
 | --- |
 | **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.
+| Authentication partners | If you register for or log into the Spotify Service 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 or devices, we may collect and use 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).
+| Technical service partners | We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g., country or region, 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.
+| Payment partners and Merchants | If you choose to pay through third parties (e.g. telco carriers) or 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
+ |
+| Advertising and marketing partners | We may get data about you from certain advertising or marketing partners.
+This may include:
+If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to an artist's merchandise store on a third party platform or to a third party ticketing website.
+Receiving this data allows us to:
+- cookie id
+- mobile device id
+- email address
+- inferences (i.e., our understanding) of your interests and preferences
+- calculate any commissions owed to us
+- analyze the effectiveness of our partnership with these merchant partners
+- understand your interests
+ |
+| Advertising and marketing partners | From certain advertising or marketing partners, we receive inferences (i.e., their understanding) of your interests and preferences.
 This allows us to deliver more relevant ads and marketing. |
+## [4\. Our purpose for using your personal data]()
+If you download the Spotify mobile app and try Spotify using a logged out user experience, we will collect limited information about your usage of the Spotify Service, including Usage Data. We do this to understand how you are accessing and using the Service. We also do this to ensure we provide the right experience for you, for example based on your country or region. If you decide to create a Spotify account to experience our service in full, then we will combine this data with your Spotify account data.
+[Top of page ↑]()
+## **4\. Our purpose for using your personal data**
 The table below sets out:
 - 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')
+- 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']()
+You can also watch our video about [Personal Data at Spotify](https://www.youtube.com/watch).
+You can also watch our video about [Personal Data at Spotify](https://www.spotify.com/privacy).
+Here is a general explanation of each "legal basis" to help you understand the table:
+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).
+    - comply with obligations under a contract with you. This includes 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.
 - **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**
+ |
+| Purpose for processing your data | Legal basis that permits the purpose | Categories of personal data used for the purpose |
 | --- | --- | --- |
+| To provide the personalized Spotify Service. (You can watch our video about [Personalization](https://youtu.be/B9iWpJfw4XY) to understand more.) |
+| To provide the Spotify Service (as defined in [Section 1 'About this Policy']().) |
 - Performance of a Contract
 - Legitimate Interest
 - Consent
+ |
 - User Data
+- Usage Data
+- Payment and Purchase Data
 - Street Address Data
+- Usage Data
 - Voice Data
+- Payment and Purchase Data
+ |
 | To understand, diagnose, troubleshoot, and fix issues with the Spotify Service. |
 - Performance of a Contract
+- Legitimate Interest
+ |
 - User Data
 - Usage Data
+ |
 | To evaluate and develop new features, technologies, and improvements to the Spotify Service. |
 - Legitimate Interest
+- Consent
+ |
 - User Data
 - Usage Data
 - Voice Data
+ |
+| For marketing, promotion, and advertising purposes. |
+| For marketing or advertising where the law requires us to collect your consent.
+For example, when we use cookies to understand your interests or the law requires consent for email marketing. |
+- Legitimate Interest
 - Consent
+ |
 - User Data
 - Usage Data
+- Contests, Surveys and Sweepstakes Data
+- Survey and Research Data
+ |
+| To comply with legal obligations and law enforcement requests. |
+| For other marketing, promotion and advertising purposes where the law does not require consent.
+For example, when we use your personal data to tailor advertising to your interests. |
+- Legitimate Interest
+ |
+- User Data
+- Usage Data
+- Survey and Research Data
+ |
+| To comply with a legal obligation that we are subject to.
+This might be:
+- an obligation under the law of the country / region you are in
+- Swedish law (because of our headquarters in Sweden), or
+- EU law that applies to us
+ |
 - Compliance with legal obligations
+- Legitimate interest
+ |
 - User Data
+- Street Address Data
 - Usage Data
+- Voice Data
 - Payment and Purchase Data
+- Survey and Research Data
+ |
+| To comply with a request from law enforcement.
+This will only apply when a competent law enforcement authority contacts us. These include the police, the courts or prisons. |
+- Compliance with legal obligations
+- Legitimate interest
+ |
+- User Data
 - Street Address Data
+- Usage Data
 - Voice Data
+- Contests, Surveys and Sweepstakes Data
+- Payment and Purchase Data
+- Survey and Research Data
+ |
+| To:
+| To fulfill contractual obligations with third parties. For example, our agreements with owners of content on the Spotify Service. |
+- 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
+- Voice Data
+- Payment and Purchase Data
+ |
+| To take appropriate action with reports of intellectual property infringement and inappropriate content. |
 - Legitimate interest
+ |
 - User Data
 - Usage Data
+- Voice Data
 - Payment and Purchase Data
+ |
 | To establish, exercise, or defend legal claims. |
 - Legitimate interest
+ |
 - User Data
+- Street Address Data
 - Usage Data
+- Voice Data
 - Payment and Purchase Data
+- Street Address Data
+- Contests, Surveys and Sweepstakes Data
+- Survey and Research Data
+ |
 | To conduct business planning, reporting, and forecasting. |
 - Legitimate Interest
 - Payment and Purchase Data
+ |
 | To process your payment. |
 - Performance of a Contract
+- Compliance with legal obligations
+ |
 - User Data
 - Payment and Purchase Data
+ |
+| To detect and prevent fraud, including fraudulent payments and fraudulent use of the Spotify Service. |
+| To detect and prevent fraud. For example, fraudulent payments and fraudulent use of the Spotify Service. |
+- Performance of a Contract
+- Compliance with legal obligations
 - Legitimate Interest
+ |
 - User Data
+- Street Address Data
 - Usage Data
 - Payment and Purchase Data
+- Street Address Data
+ |
+| To conduct research, contests, surveys, and sweepstakes. |
+| To conduct research and surveys. |
+- Performance of a Contract
 - Legitimate Interest
+- Consent
+ |
 - User Data
 - Usage Data
+- Contests, Surveys and Sweepstakes Data
+- Voice Data
+- Survey and Research Data
+ |
+## [5\. Sharing your personal data]()
+[Top of page ↑]()
+## **5\. 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.
 **Publicly available information**
 The following personal data will always be publicly available on the Spotify Service:
+- 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)
+- your profile name
+- your profile photo
+- your public playlists
+- other content you post on the Spotify Service, and any associated titles, descriptions and images
+- who you follow on the Spotify Service
+- who follows you on the Spotify Service (you can block followers)
+You or another user can share certain information on third party services, like social media or messaging platforms. This includes:
+- your profile
+- any content you post on Spotify and details about that content
+- your public playlists
+When this sharing occurs, the third party service may store a copy of it to support their features.
 **Personal data you may choose to share**
 We will only share the following personal data with those outlined in the table below:
+- 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
+- where we need to share personal data 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. For example, you can do it by selecting the appropriate setting in the Spotify Service or by giving your consent
+| **Categories of recipient** | **Reason for sharing** |
+| --- | --- |
+| 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. |
+| Categories of recipients | Categories of data you can choose to share | Reason for sharing |
+| --- | --- | --- |
+| Third party applications, services and devices you connect to your Spotify Account |
+- User Data
+- Usage Data
+ | To connect your Spotify account, 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
+- voice assistants
+You can see and remove many third party connections under 'Apps' in your account. |
+| Support community |
+- User Data
+ | To enable you to use the [Spotify Support Community service](https://community.spotify.com/).
+When you register for an account on the Spotify Support Community, we'll ask you to create a 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 |
+- User Data
+- Usage Data
+- Voice Data
+ | To share information about your use of the Spotify Service with other Spotify users. These could include your followers on Spotify.
+For example, under 'Social' settings you can choose to share your recently played artists and your playlists on your profile. You can also choose to create or join a shared playlist with other users. Shared playlists give you social recommendations based on your listening activity. |
+| Artists and record labels |
+- User Data
+ | To receive news or promotional offers from artists, record labels or other partners.
+You may choose to share your User Data for this purpose. You'll always have the option to change your mind and withdraw your consent at any time. |
 **Information we may share**
 See this table for details of who we share to and why.
+| **Categories of recipients** | **Reason for sharing** |
+| --- | --- |
+| Service providers | So they can provide their services to Spotify.
+These service providers may include those we hire to:
+| Categories of recipients | Categories of data | Reason for sharing |
+| --- | --- | --- |
+| Service providers |
+- User Data
+- Street Address Data
+- Usage Data
+- Voice Data
+- Payment and Purchase Data
+- Survey and Research Data
+ | So they can provide their services to Spotify.
+These service providers 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
+ |
+| 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:
+| Payment partners |
+- 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/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.
+- User Data
+- Payment and Purchase Data
+ |
+| Marketing Partners | To promote Spotify with our partners. We share some personal data with these partners where necessary to:
+ | So they can process your payments, and for anti-fraud purposes. |
+| Advertising partners |
+- User Data
+- Usage Data
+ | So they can help us deliver more relevant advertising to you on the Spotify Service, and help measure the effectiveness of ads.
+For example, our ad partners help us facilitate tailored advertising.
+**What is tailored advertising?**
+- This is when we use third party information to tailor ads to be more relevant to you. This is also known as interest based advertising.
+- An example of a tailored ad is when an ad partner has information suggesting you like cars. This could enable us to show you ads about cars.
+**How to control tailored advertising:**
+- You can control tailored advertising in your [account Privacy Settings](https://www.spotify.com/account/privacy/) under 'Tailored Ads'.
+- You can also control tailored advertising for some podcasts using the link in the episode's show description. This applies where the content provider is funding their podcast by inserting either tailored advertising or content-based advertising into the podcast itself. These controls are managed by the hosting platform for the podcast, which might not be Spotify.
+If you are 'opted out' of Tailored Ads in your Privacy Settings, you may still get advertising on ad-supported services (e.g. podcasts or the Free Service Option). Such advertising is based on your registration information and the content you are currently streaming on our services. For example, if you are listening to a cooking podcast, you may hear an ad for a food processor. |
+| Marketing Partners |
+- User Data
+- Usage Data
+ | To promote Spotify with our partners. We share certain User Data and Usage Data with these partners where necessary to:
 - 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
 Examples of partners include:
 - 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
+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.
+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. |
+| Hosting Platforms |
+- Usage Data
+ | Hosting platforms host podcasts so that they can deliver them to you. We share certain data, such as your IP address, with the hosting platforms when you play a podcast. Spotify owns two hosting platforms, Megaphone and Anchor. We also allow you to stream podcasts available from other hosting platforms not owned by Spotify.
+Podcast providers should explain in the show or episode description which platform is hosting the podcast. Please see the hosting platform's own privacy policy for how they use data shared with them.
+ |
+| Law enforcement and other authorities | When we believe in good faith it's necessary for us to do so, for example:
+| Other partner sharing |
+- User Data
+- Usage Data
+- Survey and Research Data
+ | 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 |
+- User Data
+- Usage Data
+ | 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. |
+| Spotify Measurement Companies |
+- User Data
+- Usage Data
+ | We share data with the following Spotify companies to measure the effectiveness of ad campaigns that run on the Spotify Service:
+- In Defense of Growth Incorporated d/b/a Podsights
+- Chartable Holding, Inc.
+ |
+| Other Spotify group companies |
+- User Data
+- Street Address Data
+- Usage Data
+- Voice Data
+- Payment and Purchase Data
+- Survey and Research Data
+ | To carry out our daily business operations and so we can maintain and provide the Spotify Service to you.
+ |
+| Law enforcement and other authorities |
+- User Data
+- Usage Data
+ | When we believe in good faith it's necessary for us to do so, for example:
 - 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.
+    - preventing death or imminent bodily harm
+ |
+| 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. |
+| Purchasers of our business |
+## [6\. Data retention and deletion]()
+- User Data
+- Street Address Data
+- Usage Data
+- Voice Data
+- Payment and Purchase Data
+- Survey and Research Data
+**Retention**
+ | If we were to sell or negotiate to sell our business to a buyer or possible buyer.
+In this case, we may transfer your personal data to a successor or affiliate as part of that transaction. |
+[Top of page ↑]()
+## **6\. Data retention**
 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:
 - maintaining the performance of the Spotify Service
 - making data-driven business decisions about new features and offerings
 - complying with our legal obligations
 - resolving disputes
+**Deletion**
+Criteria used to determine the retention periods include:
+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.
+- **How can we minimize the data retention period?** Our systems are designed to age out personal data in 90 days, unless another period is selected for legitimate business reasons.
+- **Do we need to keep data to ensure the service that users expect?** We keep personal data for an appropriate period to deliver a personalized service to our users over time. We typically keep streaming history for the life of an account, for example, to provide retrospective playlists that users enjoy (e.g. Your Summer Rewind and the end-of-year Wrapped campaign) and personalized recommendations based on current listening habits.
+- **Are users able to update or delete the data themselves?** Where users are able to see and update the personal data themselves, we keep the information for as long as the user chooses. For example, we keep your Spotify email address and other profile information until you choose to change or delete it yourself.
+- **Do we need to keep the data to uphold our rules and keep our service safe?** To help ensure user safety, protect against harmful content on our platform, and take action with reports of intellectual property infringement, we may keep data that has been removed from the Spotify Service for a limited period of time. This helps us investigate potential breaches of our [User Guidelines](https://www.spotify.com/legal/user-guidelines/) and [Platform Rules](https://www.spotify.com/platform-rules/).
+- **Is Spotify subject to a legal or contractual obligation to keep or delete the data?** Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Conversely, we will remove unlawful content if the law requires us to do so.
+Here are some examples of situations where we're legally allowed or required to keep some of your personal data:
+[Top of page ↑]()
+- 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.
+## **7\. Transfer to other countries**
+## [7\. Transfer to other countries]()
+Because of the global nature of our business, Spotify shares personal data internationally with Spotify group companies, subcontractors and partners when carrying out the activities described in this Policy. 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.
+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.
 Whenever we transfer personal data internationally, we use tools to:
 - 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
+- help to give your data the same level of protection as it has in the EU and the laws which apply where you live
+We do this using a variety of protections, as appropriate for each data transfer. For example, we use:
+[Top of page ↑]()
+- [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
+## **8\. Keeping your personal data safe**
+You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.
+We're committed to protecting our users' personal data. We put in place appropriate technical and organizational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.
+## [8\. Keeping your personal data safe]()
+We have implemented various safeguards to guard against unauthorised access and unnecessary retention of personal data in our systems. These include pseudonymisation, encryption, access, and retention policies.
+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 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
+- use a strong password which you only use for 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).
+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]()
+[Top of page ↑]()
+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.
+## **9\. Children**
+The Spotify Service has a minimum "Age Limit" in each country. The Spotify Service is not directed to children whose age:
+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.
+- 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
+The Spotify Service has a minimum 'Age Limit' in each country or region. The Spotify Service is not directed to children whose age:
+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.
+- 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
+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.
+We do not knowingly collect or use 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]()
+[Top of page ↑]()
+## **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]()
+[Top of page ↑]()
+## [**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
+- 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.
+[Top of page ↑]()