+## [**Spotify Privacy Policy**]()
+Your privacy is important. As of 30 December, we've updated our Privacy Policy to make it easier to read and comply with new U.S. laws.
+Effective as of 8 June 2022
+Effective as of 1 January 2023
+[1 About this Policy]()
+[1\. About this Policy]()
+[2 Your personal data rights and controls]()
+[2\. Your personal data rights and controls]()
+[3 Personal data we collect about you]()
+[3\. Personal data we collect about you]()
+[4 Our purpose for using your personal data]()
+[4\. Our purpose for using your personal data]()
+[5 Sharing your personal data]()
+[5\. Sharing your personal data]()
+[6 Data retention]()
+[6\. Data retention]()
+[7 Transfer to other countries]()
+[7\. Transfer to other countries]()
+[8 Keeping your personal data safe]()
+[8\. Keeping your personal data safe]()
+[9 Children]()
+[9\. Children]()
+[10 Changes to this Policy]()
+[10\. Changes to this Policy]()
+[11 How to contact us]()
+[11\. How to contact us]()
 ## **1\. About this Policy**
+This Policy describes how we process your personal data at USA Inc.
+This Privacy Policy describes how we process your personal data at Spotify USA Inc. From now on, we'll call it the 'Policy'.
 It applies to your use of:
 - 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 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
+- other Spotify services which include a link to this Policy. These include Spotify websites, Customer Service and the Community Site
 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_...**
 - 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.
 **Other resources and settings**
 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:
+- [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.
+- [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 advertising]().
 - [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
 - [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.
+Privacy laws give certain 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...** | **How?** |
+| --- | --- |
+|
+ | 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
+**Be informed**
+ |
+**Be informed of the personal data we process about you and how we process it.**
+ |
+We inform you:
+- through this Policy
 - through information provided to you as you use the Spotify Service
 - by answering your specific questions and requests when you [contact us]()
+ |
+| **Access** | **Request access to the personal data we process about you.**
+ | To request a copy of your personal data from Spotify, either:
+|
+- 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
+**Know/**
+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:
+**Access**
+ |
+**Request to know and access the personal data we process about you.**
+ |
+To request a copy of your personal data from Spotify, either:
+- use the "Download your data" tool in your account [Privacy Settings](https://www.spotify.com/account/privacy/), or
+- [contact us]()
+When you download your data you will receive the information about your data that Spotify has to provide under applicable laws. If you would like more information about how we process your personal data, you can [contact us]().
+ |
+|
+**Correction**
+ |
+**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]().
+ |
+|
+**Deletion**
+ |
+**Request that we delete certain of your personal data.**
+For example, you can ask us to delete your personal data:
 - 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
 - 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
+ | There are several ways you can erase personal data from Spotify:
+ |
+- 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
+There are several ways you can delete personal data from Spotify:
+- to remove audio content from your profile select the relevant content and choose to remove it. For example, you can remove playlists from your profile, or remove a track from your playlist
+- to request deletion of your other personal data from Spotify (and thus close your account), 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]() to request erasure or reach out to customer support via our [chat bot](https://support.spotify.com/us/contact-spotify-privacy/)
+ |
+| **Restriction** | **Request that we stop processing all or some of your personal data.**
+|
+**Right to Limit**
+ |
+**Under California law, request that we limit the processing of sensitive personal data if we are using or disclosing it for purposes other than those specified in Section 7027(m) of the CCPA Regulations.**
+ |
+Currently, we are not using or disclosing any sensitive personal data for purposes other than those specified in Section 7027(m) of the CCPA Regulations.
+ |
+|
+**Restriction**
+ |
+**Request that we stop processing all or some of your personal data.**
 You can do this if:
 - 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
+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 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:
 - Spotify is processing your personal data on the legal basis of legitimate interests, or
+- Spotify is processing your personal data for direct marketing
+- Spotify is processing your personal data for tailored advertising.
+ | 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
+To exercise your right to object, you can:
+- use controls on the Spotify Service to switch off or adjust some features which process your personal data. See the end of this section on how you can control tailored advertising
+- [contact us]()
+ |
+| **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:
+|
+**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 bases of consent or performance of contract. However Spotify will try to honor any request to the extent possible.
+ |
+For information about how to exercise the right to portability, 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. |
+**Requests, generally**
+We will not discriminate against you for exercising any of your rights under any privacy law. To verify a consumer request to know, request to delete, and request to correct, we ask you to provide certain details related to your Spotify account. Please note, if you do not have a Spotify account we will not have enough information about you to verify your identity and respond to your requests, as we do not keep sufficient information necessary to re-identify and link you to a prior visit to the Spotify Service where data may have been collected. As such, we will be unable to verify and honor your requests.
+**Household requests**
+If all the members of a household make an access, correction or deletion request, we will respond as if the requests are individual requests.
+**Requests made through agent**s
+You may designate, in writing or through a power of attorney (in accordance with local law), an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
+**Appeals process**
+If your request is denied you may have the right to appeal the denial in accordance with the instructions provided to you when the denial was made.
+#### **Tailored advertising controls**
+What is tailored advertising?
+- This is when we use information about you to tailor ads to be more relevant to you. This is also known as interest based advertising or cross-context behavioral advertising.
+- An example of tailored advertising is when an advertising 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 inserts advertising into the podcast to fund it. The hosting provider, which might not be Spotify, manages these controls for the podcast.
+If you are 'opted out' of Tailored Ads in your [Privacy Settings](https://www.spotify.com/account/privacy/), you may still get advertising. This can include on our free Service Option, as well as our paid Service Option, as applicable (for example, advertising in podcasts). This type of advertising is based on your registration information and what you are currently listening to on our services. For example, if you are listening to a cooking podcast, you may hear an ad for a food processor.
+**Metrics**
+The following chart contains statistics about global verifiable requests we received from consumers between 1 January and 31 December 2021:
+| **Type of request** | **Received** | **Complied** | **Denied** | **Average response rate** |
+| --- | --- | --- | --- | --- |
+|
+Right to Know / Access
+ |
+,465
+ |
+,465
+ |
+ |
+days
+ |
+|
+Request to Delete
+ |
+,298,607
+ |
+,298,607
+ |
+ |
+.5 days
+ |
 [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).
+These tables set out the categories of personal data we collect from you. 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 |
+| **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 that enables you to use the Spotify Service.
+|
+**Categories**
+ |
+**Categories under CCPA**
+ |
+**Description**
+ |
+|
+User Data
+ |
+Identifiers
+ |
+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
+- password
 - phone number
 - date of birth
 - gender
 - street address (see further details below)
 - country
+- university/college (for Spotify Premium Student)
 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 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:
+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
+ |
+Identifiers
+ |
+We may ask for and process your street address for the following reasons:
 - to check eligibility for a Service Option
 - 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 application to help you verify your address, such as Google Maps. |
+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 and processed about you when you're accessing or using the Spotify Service.
+|
+**Categories**
+ |
+**Categories under CCPA**
+ |
+**Description**
+ |
+|
+Usage Data
+ |
+Internet or other electronic network activity information; and
+Inferences
+ |
+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:
     - search queries
     - streaming history
     - playlists you create
     - your library
     - 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 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:
     - device IDs
     - language
     - information enabling digital rights management
     - operating system
     - Spotify application version
 - 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
+    - devices your operating system makes available 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**
 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 |
+Motion-generated or orientation-generated device sensor data if needed to provide features of the Spotify Service that require this data. This is data which your device collects about the way you move or hold your device.
+ |
+| **Additional data you may choose to give us** |
 | --- |
+| **Categories** | **Description** |
+| Voice Data
+ | 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/).
+|
+**Categories**
+ |
+| 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.
+**Categories under CCPA**
+ |
+**Description**
+ |
+|
+Voice Data
+ |
+Internet or other electronic network activity information
+ |
+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/legal/voice-controls/).
+ |
+|
+Payment and Purchase Data
+ |
+Commercial information
+ |
+If you make any purchases from Spotify or sign up for a paid Service Option or a trial, we will need to process your payment data.
 The exact personal data collected and used will vary depending on the payment method. It will include information such as:
 - name
 - date of birth
 - 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
+- if using a debit or credit card, the card type, expiration date, and certain digits of your card number
+    Note: For security, we never store your full card number
 - ZIP/postal code
 - mobile phone number
 - details of your purchase and payment history
+ |
+| 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. |
+|
+| Third party sources that we collect your data from |
+Survey and Research Data
+ |
+Identifiers; and
+other information you share
+ |
+When you respond to a survey or take part in user research, we collect and use the personal data you provide.
+ |
+We receive some of the data mentioned above from third parties. The below table describes the categories of those third parties.
+| **Third party sources that we receive your data from** |
 | --- |
+| **Categories of third parties** | **Description** |
+| 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.
+|
+**Categories of third parties**
+ |
+**Description**
+ |
+**Data categories**
+ |
+|
+Authentication partners
+ |
+If you register for or log into the Spotify Service using another service, that service will send your information to us. This information helps create your account with us.
+ |
+User Data
+ |
+|
+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 device, we may collect and use information from them. This collection is 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
+- services or platforms such as voice assistants or content platforms
+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. 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 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.
+We'll ask your permission before we collect your information from certain third parties.
+ |
+User Data
+Usage Data
+ |
+|
+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.
+We also work with security service providers who help us protect user accounts.
+ |
+User Data
+Usage Data
+ |
+|
+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
 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:
 - 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. |
+Payment and Purchase Data
+ |
+|
+Advertising and marketing partners
+ |
+We receive inferences from certain advertising or marketing partners. These inferences are the partners' understanding of your interests and preferences.
+This allows us to deliver more relevant ads and marketing.
+ |
+Usage Data
+ |
+|
+Acquired companies
+ |
+We may receive data about you from companies we acquire. This is to enhance our services, products, and offerings.
+ |
+User Data
+Usage 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**
     - 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 Spotify Service (as defined in [Section 1 'About this Policy']().) |
+- Performance of a Contract
+- Legitimate Interest
+- Consent
+|
+To provide the Spotify Service in accordance with our contract with you. See [Section 1 'About this Policy']() for what we mean by the Spotify Service.
+For example, when we use your personal data to:
+- set up an account for you
+- personalize your account, or
+- provide the Spotify app when you download it onto your device
+ |
+Performance of a Contract
+ |
 - User 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
+To provide further parts of the Spotify Service.
+For example, when we use your personal data to enable you to share a link to Spotify content with someone else.
+ |
+Legitimate Interest
+Our legitimate interests here include:
+- keeping the Spotify Service running and functional
+- allowing users to access and use the Spotify Service
+ |
 - User Data
+- Street Address Data
 - Usage Data
+- Voice Data
+- Payment and Purchase Data
+ |
+| To evaluate and develop new features, technologies, and improvements to the Spotify Service. |
+|
+- Legitimate Interest
+To provide certain additional voluntary features of the Spotify Service. When this is the case, we will clearly ask for your consent.
+ |
+Consent
+ |
 - User Data
 - Usage Data
+- Survey and Research Data
+- Payment and Purchase Data
+ |
+|
+To understand, diagnose, troubleshoot, and fix issues with the Spotify Service.
+For example, we use your personal data to:
+- respond to your messages when you contact customer services
+- spot unusual data or behavior in our logs which might indicate a bug or other issue, or
+- check and verify accounts to find and prevent unauthorized users
+ |
+Performance of a Contract
+ |
+- User Data
+- Usage Data
+ |
+|
+To evaluate and develop new features, technologies, and improvements to the Spotify Service.
+For example:
+- we use personal data to develop and improve our personalized recommendation algorithms
+- we analyze how our users react to a particular new feature and see whether we should make any changes
+ |
+Legitimate Interest
+Our legitimate interests here include developing and improving products and features for our users.
+ |
+- User Data
+- Usage Data
 - Voice Data
+- Survey and Research Data
+ |
+| 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. |
+|
+- Consent
+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.
+ |
+Consent
+ |
 - User Data
 - Usage Data
 - Survey and Research Data
+ |
+| 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
+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
+Our legitimate interests here include using advertising to fund the Spotify Service, so that we can offer much of it for free.
+ |
 - User Data
 - Usage Data
 - Survey and Research Data
+ |
+| To comply with a legal obligation that we are subject to.
+|
+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
+For example, when we use your date of birth when required for age verification purposes.
+ |
+- Compliance with legal obligations
+Compliance with legal obligations
+ |
 - 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
+To comply with a request from law enforcement, courts, or other competent authorities.
+ |
+Compliance with legal obligations, and legitimate interest
+Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.
+ |
 - User Data
 - Street Address Data
 - Usage Data
 - Voice Data
 - Payment and Purchase Data
 - Survey and Research Data
+ |
+| To fulfill contractual obligations with third parties. For example, our agreements with owners of content on the Spotify Service. |
+|
+- Legitimate interest
+To fulfill contractual obligations with third parties.
+For example, when we provide pseudonymized data about our users' listening because we have an agreement with a Spotify rightsholder to do so.
+Pseudonymized data means that your data is identified by a code rather than your name or other directly identifying information.
+ |
+Legitimate Interest
+Our legitimate interests here include:
+- maintaining our relationships with artists so that we can provide the Spotify Service
+- maintaining our relationships with other third parties for the same reason
+ |
 - 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
+To take appropriate action with reports of intellectual property infringement and inappropriate content.
+ |
+Legitimate Interest
+Our legitimate interests here include protecting intellectual property and original content.
+ |
 - User Data
 - Usage Data
 - Voice Data
 - Payment and Purchase Data
+ |
+| To establish, exercise, or defend legal claims. |
+|
+- Legitimate interest
+To establish, exercise, or defend legal claims.
+For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.
+ |
+Legitimate Interest
+Our legitimate interests here include:
+- seeking legal advice
+- protecting ourselves, our users or others in legal proceedings
+ |
 - User Data
 - Street Address Data
 - Usage Data
 - Voice Data
 - Payment and Purchase Data
 - Survey and Research Data
+ |
+| To conduct business planning, reporting, and forecasting. |
+|
+- Legitimate Interest
+To conduct business planning, reporting, and forecasting.
+For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.
+ |
+Legitimate Interest
+Our legitimate interests here include researching and planning so that we can keep running our business successfully.
+ |
 - User Data
 - Usage Data
 - Payment and Purchase Data
+ |
+| To process your payment. |
+|
+- Performance of a Contract
+To process your payment.
+For example, when we use your personal data to let you purchase a Spotify subscription.
+ |
+Performance of a Contract, and consent
+ |
 - User Data
 - Payment and Purchase Data
+- Street Address Data
+ |
+| To detect and prevent fraud. For example, fraudulent payments and fraudulent use of the Spotify Service. |
+|
+- Legitimate Interest
+To detect and prevent fraud.
+For example, when we analyze Usage Data to check for fraudulent use of the Spotify Service.
+ |
+Legitimate Interest
+Our legitimate interests here include protecting the Spotify Service and our users against fraud and other illegal activity.
+ |
 - User Data
 - Street Address Data
 - Usage Data
 - Payment and Purchase Data
+ |
+| To conduct research and surveys. |
+|
+- Legitimate Interest
+To conduct research and surveys.
+For example, when we contact our users to ask for your feedback.
+ |
+Legitimate Interest
+Our legitimate interests here include to understand more about how users think about and use the Spotify Service.
+ |
 - User Data
 - Usage Data
 - Voice Data
 - Survey and Research 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.
+This section sets out who receives personal data which is 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:
+The following personal data will always be publicly available on the Spotify Service (except to any user you have blocked):
 - 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)
+- who follows you on the Spotify Service
 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:
+We will only share the following personal data with those outlined in the table below
+- 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
+- where you have chosen to use a Spotify Service feature, or a third party application, service or device, and we need to share personal data to enable this, 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 recipients | Categories of data you can choose to share | Reason for sharing |
+| **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 |
+|
+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.
+ |
+To connect your Spotify account, or so that you can 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 |
+You can see and remove many third party connections under '[Apps](https://www.spotify.com/account/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 |
+ |
+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 |
+ |
+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. |
+ |
+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](https://www.spotify.com/account/profile/).
+ |
 **Information we may share**
 See this table for details of who we share to and why.
+| Categories of recipients | Categories of data | Reason for sharing |
+| **Categories of recipients** | **Categories of data** | **Reason for sharing** |
 | --- | --- | --- |
+| Service providers |
+|
+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.
+ |
+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
+- verify your eligibility for certain types of Service Options (e.g., Spotify Premium Student)
+ |
+| Payment partners |
+|
+Payment partners
+ |
 - User Data
 - Payment and Purchase Data
+ | So they can process your payments, and for anti-fraud purposes. |
+| Advertising partners |
+ |
+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?**
+So they can help us deliver more relevant advertising to you on the Spotify Service, and help measure the effectiveness of ads.
+- 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.
+For example, our ad partners help us facilitate tailored advertising.
+**How to control tailored advertising:**
+With respect to Spotify Service users under the age of 16, we do not share personal data to advertising partners by default.
+- 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 |
+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:
+ |
+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. |
+| Hosting Platforms |
+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 that we think you'll find relevant.
+- Usage Data
+With respect to Spotify Service users under the age of 16, we do not share personal data to marketing partners by default.
+ | 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.
+Ticketing and event partners
+ |
+| 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
+For every event for which we sell tickets, we will need to share your name, email or other order details to our event partners such as ticketing agent or venue box office where the event is taking place so that you can check-in as a verifiable guest who purchased tickets through Spotify's ticketing platform.
+ |
+|
+Hosting Platforms
+ |
 - 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 |
+ |
+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. 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. See the hosting platform's own privacy policy for how they use data shared with them.
+ |
+|
+Academic researchers
+ |
 - 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.
+For activities such as statistical analysis and academic study, but only in a pseudonymized format.
+ |
+| Other Spotify group companies |
+|
+Other Spotify group companies, including companies that Spotify acquires
+ |
 - 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 |
+To carry out our daily business operations and so we can maintain, improve and provide the Spotify Service and acquired companies' services to you.
+For example:
+- enabling our employees who work for different group companies to develop and improve features for the Spotify Service
+- sharing data with our measurement companies to measure the effectiveness of ad campaigns that run on the Spotify Service
+- sharing data with our podcast companies to better understand user listening trends
+ |
+|
+Law enforcement and other authorities, or other parties to litigation
+ |
 - User Data
 - Usage Data
+ | When we believe in good faith it's necessary for us to do so, for example:
+ |
+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
+ |
+| Purchasers of our business |
+|
+Purchasers of our business
+ |
 - User Data
 - Street Address Data
 - Usage Data
 - Voice Data
 - Payment and Purchase Data
 - Survey and Research Data
+ | 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. |
+ |
+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
+Here are some of the categories of our retention periods:
+- **Data retained until you remove it**
+It's your right to request that we delete certain of your personal data. See the section on 'Deletion' in [Section 2 'Your personal data rights and controls']() for more information.
+- **Data that expires after a specific period of time**
+We have set certain retention periods so that some data expires after a specific period of time.
+- **Data retained until your Spotify account is deleted**
+We keep some data until your Spotify account is deleted. When your Spotify account is deleted, your data is deleted or anonymized.
+- **Data retained for extended time periods for limited purposes**
+After your account is deleted, we keep some data for a longer time period but for very limited purposes.
 Criteria used to determine the retention periods include:
+- **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/).
+- **What is the appropriate retention period to carry out our purpose?** Our systems are designed to automatically 'age out' data based on a defined retention period. We choose the retention period based on its legitimate business purpose.
+- **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 and personalized recommendations that take listening habits into account. For example, Your Summer Rewind and the end-of-year Wrapped campaign.
+- **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.
+- **Do we need to keep the data to uphold our rules and keep our service safe?** We may keep data that has been removed from the Spotify Service for a limited period of time. This is:
+    - to help ensure user safety
+    - to protect against harmful content on our platform
+    - to take action with reports of intellectual property infringement
+This also 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.
 [Top of page ↑]()
 ## **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.
 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 and the laws which apply where you live
+- help to give your data the same level of protection as it has in the EU
+To ensure each data transfer complies with applicable EU legislation, we use the following legal mechanisms:
+- [Standard Contractual Clauses](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/) ('**SCCs**'). These clauses require the other party to protect your data and to provide you with EU-level rights and protections. For example, we use SCCs to transfer the personal data described in [Section 3 'Personal data we collect about you']() to our hosting provider which uses servers in the US. You can exercise your rights under the Standard Contractual Clauses by [contacting us]() or the third party who processes your personal data.
+- [Adequacy Decisions](https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). This means that we transfer personal data to countries outside of the European Economic Area which have adequate laws to protect personal data, as determined by the European Commission. For example, we transfer the personal data described in [Section 3 'Personal data we collect about you']() to vendors based in the United Kingdom, Canada, Japan, Republic of Korea and Switzerland.
+We also identify and use additional protections as appropriate for each data transfer. For example, we use:
+- technical protections, such as encryption and pseudonymization
+- policies and processes to challenge disproportionate or unlawful government authority requests
 [Top of page ↑]()
 ## **8\. Keeping your personal data safe**
 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.
+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 have put various safeguards in place to guard against unauthorized access and unnecessary retention of personal data in our systems. These include pseudonymization, encryption, access, and retention policies.
 To protect your user account, we encourage you to:
 - 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).
+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.
+If other individuals have access to your Spotify account, then they can access personal data, controls and the Spotify Service available in your account. For example, you might have allowed someone to use your account on a shared device.
+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.
+It's your responsibility to only allow individuals 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 personalized recommendations and be included in your data download.
 [Top of page ↑]()
 ## **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 or region. The Spotify Service is not directed to children whose age:
+- is under the age of 13 years, or
+- is under the age of 13 years
 - makes it illegal to process their personal data, or
 - requires parental consent to process their personal data
+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.
+We do not knowingly collect or use personal data from children under the applicable Age Limit. If you're under the Age Limit, 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 you're a parent of a child under the Age Limit and become aware that your child has provided personal data to Spotify, [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.
+When using a shared device on the main Spotify Service, be cautious about playing or recommending any inappropriate content to individuals under 18 years old.
 [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.
 [Top of page ↑]()
+## [**11\. How to contact us**]()
+## **11\. How to contact us**
 For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:
 - 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
+Spotify USA Inc. is the data controller of personal data processed under this Policy.
 © Spotify USA Inc.
 [Top of page ↑]()

Privacy Policy

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