Privacy Policy

20240801_rev01 · COMPARED WITH 20240701_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE

Full text changes — 20240701_rev01 to 20240801_rev01

1Your privacy is important. As of 27 June, we've updated our Privacy Policy to make it easier to read and include additional detail.
2
31Effective as of 27 June 2024
42
5[1\. About this Policy]()
3## **1\. About this Policy**
64
7[2\. Your personal data rights and controls]()
8
9[3\. Personal data we collect about you]()
10
11[4\. Our purpose for using your personal data]()
12
13[5\. Disclosing your personal data]()
14
15[6\. Data retention]()
16
17[7\. Transfer to other countries]()
18
19[8\. Keeping your personal data safe]()
20
21[9\. Children]()
22
23[10\. Privacy Request Metrics]()
24
25[11\. Changes to this Policy]()
26
27[12\. How to contact us]()
28
29## [1\. About this Policy]()
30
315This Privacy Policy describes how we process your personal data at Spotify USA Inc. From now on, we'll call it the 'Policy'.
326
337It applies to your use of:
348
359- all Spotify streaming services as a user. For example this includes:
3610 - your use of Spotify on any device
6236 - choose whether to show your recently played artists on your public profile
6337
6438On the 'Explicit Content' setting you can control whether explicit-rated content can be played on your Spotify account.
6539
6640- [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.
6741
68## [2\. Your personal data rights and controls]()
42## **2\. Your personal data rights and controls**
6943
7044Privacy laws give certain rights to individuals over their personal data.
7145
7246The table below explains:
7347
7448- your rights
9569**Be informed of the personal data we process about you and how we process it.**
9670
9771 |
9872
9973We inform you:
10074
101• through this Policy
75- through this Policy
76- through information provided to you as you use the Spotify Service
77- by answering your specific questions and requests when you [contact us]()
10278
103• through information provided to you as you use the Spotify Service
104
105• by answering your specific questions and requests when you [contact us]()
106
10779 |
10880|
10981
11082**Know/**
11183
11284**Access**
11688**Request to know and access the personal data we process about you.**
11789
11890 |
11991
12092To request a copy of your personal data from Spotify, either:
12193
122• use the 'Download your data' tool in your account [Privacy Settings](https://www.spotify.com/account/privacy/), or
94- use the 'Download your data' tool in your account [Privacy Settings](https://www.spotify.com/account/privacy/), or
95- [contact us]()
12396
124• [contact us]()
125
12697When 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]().
12798
12899 |
129100|
130101
131102**Correction**
146117 |
147118
148119**Request that we delete certain of your personal data.**
149120
150121Please note there are situations where Spotify is unable to delete your data, for example when:
151122
152• it's still necessary to process the data for the purpose we collected it for
123- it's still necessary to process the data for the purpose we collected it for
124- we have an overriding interest in continuing to process the data, for example where we need the data to protect our services from fraud
125- Spotify has a legal obligation to keep the data, or
126- Spotify needs the data to establish, exercise or defend legal claims. For example, if there's an unresolved issue relating to your account
153127
154• we have an overriding interest in continuing to process the data, for example where we need the data to protect our services from fraud
155
156• Spotify has a legal obligation to keep the data, or
157
158• Spotify needs the data to establish, exercise or defend legal claims. For example, if there's an unresolved issue relating to your account
159
160128 |
161129
162130There are several ways you can delete personal data from Spotify:
163131
164• to remove audio content you have saved, select the relevant content and choose to remove it. For example you can remove a track from your playlist or remove an artist you've saved to your Library
132- to remove audio content you have saved, select the relevant content and choose to remove it. For example you can remove a track from your playlist or remove an artist you've saved to your Library
133- to request deletion of your account data from Spotify and 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]()'
134- for any other deletion requests, you can [contact us]() or reach out to customer support via our [chat bot](https://support.spotify.com/us/contact-spotify-privacy/)
165135
166• to request deletion of your account data from Spotify and 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]()'
167
168• for any other deletion requests, you can [contact us]() or reach out to customer support via our [chat bot](https://support.spotify.com/us/contact-spotify-privacy/)
169
170136 |
171137|
172138
173139**Opt-out of tailored advertising**
174140
175141 |
244210You 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.
245211
246212**Appeals process**
247213
248214If 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.
249215
250#### [Tailored advertising controls]()
216#### **Tailored advertising controls**
251217
252218What is tailored advertising?
253219
254220- This is when we use information about your use of our services and other websites and mobile apps to tailor ads to be more relevant to you. This is also known as interest based advertising, targeted advertising, or 'sharing' for purposes of cross-context behavioral advertising.
255221- An example of tailored advertising is when an advertising partner provides us with information indicating that you may be interested in cars. This could enable us to show you ads about cars.
256222
264230If you are 'opted out' of tailored advertising in your [Privacy Settings](https://www.spotify.com/account/privacy/), you will receive less relevant advertising, including 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.
265231
266232Appropriate age for tailored advertising:
267233
268234- Younger users may have tailored advertising turned off by default. When you reach the appropriate age, you will start to receive tailored advertising . When this happens, you will receive a message within the Spotify Service to let you know. This message will contain a link to the [Privacy Settings](https://www.spotify.com/account/privacy/) where you can change your preferences or 'opt-out' of tailored advertising at any time under Tailored Ads.
269235
270## [3\. Personal data we collect about you]()
236## **3\. Personal data we collect about you**
271237
272238These 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).
273239
274240|
275241**Collected when you sign up for the Spotify Service**
276242
304270 |
305271
306272Personal data that we need to create your Spotify account and that enables you to use the Spotify Service.
307273
308274The 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:
309275
310• profile name
276- profile name
277- email address
278- password
279- phone number
280- date of birth
281- gender
282- street address (see further details below)
283- country
284- university/college (for Spotify Premium Student)
311285
312• email address
313
314• password
315
316• phone number
317
318• date of birth
319
320• gender
321
322• street address (see further details below)
323
324• country
325
326• university/college (for Spotify Premium Student)
327
328286We receive some of this data from you e.g. from the sign up form or account page.
329287
330288We 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.
331289
332290 |
333291|
339297Geolocation data
340298
341299 |
342300
343301We may ask for and process your street address for the following reasons:
344302
345• to check eligibility for a Service Option
303- to check eligibility for a Service Option
304- to deliver notices which are required by law
305- to deliver support options
306- for billing and tax administration
307- to deliver physical goods or gifts which you have requested
346308
347• to deliver notices which are required by law
348
349• to deliver support options
350
351• for billing and tax administration
352
353• to deliver physical goods or gifts which you have requested
354
355309In some cases, we may use a third party application to help you verify your address, such as Google Maps.
356310
357311 |
358312
359313|
360314**Collected through your use of the Spotify Service**
395349There are a few types of information this includes, listed in the following sections.
396350
397351**Information about how you use Spotify**
398352
399353Examples include:
400354
401• information about your Spotify Service Option
355- information about your Spotify Service Option
356- your actions with the Spotify Service (including date and time), such as:
357 - search queries
358 - streaming history
359 - playlists you create
360 - your library
361 - browsing history
362 - account settings
363 - interactions with other Spotify users
364- your use of third party services, devices and applications in connection with the Spotify Service
365- inferences (i.e., our understanding) of your interests and preferences based on your usage of the Spotify Service
366- content you provide when participating in Spotify promotions, such as contests or sweepstakes
367- content you post to any part of the Spotify Service. For example: images, audio, text, titles, descriptions, communications, and other types of content
402368
403• your actions with the Spotify Service (including date and time), such as:
404
405◦ search queries
406
407◦ streaming history
408
409◦ playlists you create
410
411◦ your library
412
413◦ browsing history
414
415◦ account settings
416
417◦ interactions with other Spotify users
418
419◦ your use of third party services, devices and applications in connection with the Spotify Service
420
421• inferences (i.e., our understanding) of your interests and preferences based on your usage of the Spotify Service
422
423• content you provide when participating in Spotify promotions, such as contests or sweepstakes
424
425• content you post to any part of the Spotify Service. For example: images, audio, text, titles, descriptions, communications, and other types of content
426
427369**Your technical data**
428370
429371Examples include:
430372
431• URL information
373- URL information
374- online identifiers such as [cookie data](https://www.spotify.com/legal/cookies-policy/) and IP addresses
375- information about the devices you use such as:
376 - device IDs
377 - network connection type (e.g. wifi, 4G, LTE, Bluetooth)
378 - provider
379 - network and device performance
380 - browser type
381 - language
382 - information enabling digital rights management
383 - operating system
384 - Spotify application version
385- 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:
386 - devices on your wifi network (such as speakers) which can connect to the Spotify Service
387 - devices your operating system makes available when connecting via Bluetooth, plugin, and installation
388 - Spotify partner applications to determine whether the application is installed on your device
432389
433• online identifiers such as [cookie data](https://www.spotify.com/legal/cookies-policy/) and IP addresses
434
435• information about the devices you use such as:
436
437◦ device IDs
438
439◦ network connection type (e.g. wifi, 4G, LTE, Bluetooth)
440
441◦ provider
442
443◦ network and device performance
444
445◦ browser type
446
447◦ language
448
449◦ information enabling digital rights management
450
451◦ operating system
452
453◦ Spotify application version
454
455• 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:
456
457◦ devices on your wifi network (such as speakers) which can connect to the Spotify Service
458
459◦ devices your operating system makes available when connecting via Bluetooth, plugin, and installation
460
461◦ Spotify partner applications to determine whether the application is installed on your device
462
463390**Your general (non-precise) location**
464391
465392Your 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.
466393
467394We need this to:
468395
469• meet geographic requirements in our agreements with the owners of content on the Spotify Service
396- meet geographic requirements in our agreements with the owners of content on the Spotify Service
397- deliver content and advertising that's relevant to you
470398
471• deliver content and advertising that's relevant to you
472
473399**Your device sensor data**
474400
475401Motion-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.
476402
477403 |
478404
505431 |
506432
507433If 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.
508434
509435The exact personal data collected and used will vary depending on the payment method. It will include information such as:
510436
511• name
437- name
438- date of birth
439- payment method type (e.g. credit or debit card)
440- 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
441- ZIP/postal code
442- mobile phone number
443- details of your purchase and payment history
512444
513• date of birth
514
515• payment method type (e.g. credit or debit card)
516
517• if using a debit or credit card, the card type, expiration date, and certain digits of your card number
518Note: For security, we never store your full card number
519
520• ZIP/postal code
521
522• mobile phone number
523
524• details of your purchase and payment history
525
526445 |
527446|
528447
529448Survey and Research Data
530449
531450 |
580499 |
581500
582501If 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.
583502
584503These third party apps, services or devices may include:
585504
586• social media
505- social media
506- devices including:
507 - audio (e.g. speakers and headphones)
508 - smart watches
509 - televisions
510 - mobile phones and tablets
511 - automotive (e.g. cars)
512 - games consoles
513- services or platforms such as voice assistants or content platforms
587514
588• devices including:
589
590◦ audio (e.g. speakers and headphones)
591
592◦ smart watches
593
594◦ televisions
595
596◦ mobile phones and tablets
597
598◦ automotive (e.g. cars)
599
600◦ games consoles
601
602• services or platforms such as voice assistants or content platforms
603
604515We'll ask your permission before we collect your information from certain third parties.
605516
606517 |
607518
608519User Data
609520
636547 |
637548
638549If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners.
639550
640551This allows us to:
641552
642• send you invoices
553- send you invoices
554- process your payment
555- give you what you've purchased
643556
644• process your payment
645
646• give you what you've purchased
647
648557If 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.
649558
650559Receiving this data allows us to:
651560
652• calculate any commissions owed to us
561- calculate any commissions owed to us
562- analyze the effectiveness of our partnership with these merchant partners
563- understand your interests
653564
654• analyze the effectiveness of our partnership with these merchant partners
655
656• understand your interests
657
658565 |
659566
660567Payment and Purchase Data
661568
662569 |
663570|
690597Usage Data
691598
692599 |
693600
694601If 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.
695602
696## [4\. Our purpose for using your personal data]()
603## **4\. Our purpose for using your personal data**
697604
698605The table below sets out:
699606
700607- our purpose for processing your personal data
701608- categories of personal data which we use for each purpose. See more about these categories in [Section 3 'Personal data we collect about you']()
702609
703You can also watch our video about [Personal Data at Spotify](https://www.spotify.com/privacy).
704
705610|
706611**Purpose for processing your data**
707612
708613 |
709614
710615**Categories of personal data used for the purpose**
948853• Usage Data
949854
950855• Survey and Research Data
951856
952857 |
953858
954## [5\. Disclosing your personal data]()
859## **5\. Disclosing your personal data**
955860
956861This section sets out who receives personal data which is collected or generated through your use of the Spotify Service.
957862
958863**Publicly available information**
959864
960865The following personal data will always be publicly available on the Spotify Service (except to any user you have blocked):
12691174• Usage Data
12701175
12711176 |
12721177
12731178When we believe in good faith it's necessary for us to do so, for example:
12741179
1275• to comply with a legal obligation
1180- to comply with a legal obligation
1181- to respond to a valid legal process (such as a search warrant, court order, or subpoena)
1182- for our own or a third party's justifiable interest, relating to:
1183 - national security
1184 - law enforcement
1185 - litigation (a court case)
1186 - criminal investigation
1187 - protecting someone's safety
1188 - preventing death or imminent bodily harm
12761189
1277• to respond to a valid legal process (such as a search warrant, court order, or subpoena)
1278
1279• for our own or a third party's justifiable interest, relating to:
1280
1281◦ national security
1282
1283◦ law enforcement
1284
1285◦ litigation (a court case)
1286
1287◦ criminal investigation
1288
1289◦ protecting someone's safety
1290
1291◦ preventing death or imminent bodily harm
1292
12931190 |
12941191|
12951192
12961193Purchasers of our business
12971194
12981195 |
13121209If we were to sell or negotiate to sell our business to a buyer or possible buyer.
13131210
13141211In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.
13151212
13161213 |
13171214
1318## [6\. Data retention]()
1215## **6\. Data retention**
13191216
13201217We 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:
13211218
13221219- maintaining the performance of the Spotify Service
13231220- making data-driven business decisions about new features and offerings
13241221- complying with our legal obligations
13251222- resolving disputes
13261223
13271224Here are some of the categories of our retention periods, and the criteria we use to determine them:
13281225
1329- \*_Data retained until you remove it_
1226- **Data retained until you remove it**
13301227
13311228It'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, and the circumstances in which we can act on your request.
13321229
13331230You can also delete certain personal data directly from the Spotify Service: for example, you can edit or delete your profile picture. Where users are able to see and update the personal data themselves, we keep the information for as long as the user chooses unless one of the limited purposes described below applies.
13341231
1335- \*_Data that expires after a specific period of time_
1232- **Data that expires after a specific period of time**
13361233
13371234We have set certain retention periods so that some data expires after a specific period of time. For example, personal data you may input as part of search queries is generally deleted after 90 days.
13381235
1339- \*_Data retained until your Spotify account is deleted_
1236- **Data retained until your Spotify account is deleted**
13401237
13411238We keep some data until your Spotify account is deleted. Examples of this include your Spotify username and profile information. We also 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 Time Capsule or Your Summer Rewind). When your Spotify account is deleted, this category of data is deleted or de-identified.
13421239
1343- \*_Data retained for extended time periods for limited purposes_
1240- **Data retained for extended time periods for limited purposes**
13441241
13451242After your account is deleted, we keep some data for a longer time period but for very limited purposes. For example, we may be subject to legal or contractual obligations that require this. These may include mandatory data retention laws, government orders to preserve data relevant to an investigation, or data kept for the purposes of litigation. We may also keep data that has been removed from the Spotify Service for a limited period of time. This could be:
13461243
13471244- to help ensure user safety, or
13481245- to protect against harmful content on our platform.
13491246
13501247This 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/). On the other hand, we will remove unlawful content if the law requires us to do so.
13511248
1352## [7\. Transfer to other countries]()
1249## **7\. Transfer to other countries**
13531250
13541251Because of the global nature of our business, Spotify transfers personal data internationally with Spotify group companies, subcontractors and partners when carrying out the activities described in this Policy.
13551252
13561253Whenever we transfer personal data internationally, we use tools to make sure the data transfer complies with applicable law.
13571254
13581255We also identify and use additional protections as appropriate for each data transfer. For example, we use:
13591256
13601257- technical protections, such as encryption and pseudonymization
13611258- policies and processes to challenge disproportionate or unlawful government authority requests
13621259
1363## [8\. Keeping your personal data safe]()
1260## **8\. Keeping your personal data safe**
13641261
13651262We'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.
13661263
13671264We 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.
13681265
13691266To protect your user account, we encourage you to:
13771274You 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).
13781275
13791276If 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.
13801277
13811278It'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.
13821279
1383## [9\. Children]()
1280## **9\. Children**
13841281
13851282Note: This Policy doesn't apply to Spotify Kids except where the [Spotify Kids Privacy Policy](https://www.spotify.com/legal/kids-privacy-policy/) says so. Spotify Kids is a separate Spotify application.
13861283
13871284The Spotify Service has a minimum 'Age Limit' in each country or region. The Spotify Service is not directed to children whose age:
13881285
13891286- is under the age of 13 years
13951292If 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]().
13961293
13971294If 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.
13981295
13991296When using a shared device on the main Spotify Service, be cautious about playing or recommending any inappropriate content to individuals under 18 years old.
14001297
1401## [10\. Privacy Request Metrics]()
1298## **10\. Privacy Request Metrics**
14021299
14031300The following chart contains statistics about global requests we received from users between 1 January and 31 December 2023:
14041301
1405<table><tbody><tr><td><p><strong>Type of request</strong></p></td><td><p><strong>Received</strong></p></td><td><p><strong>Complied</strong></p></td><td><p><strong>Denied</strong></p></td><td><p><strong>Average response rate</strong></p></td></tr><tr><td><p>Right to Know / Access</p></td><td><p>2,375,576</p></td><td><p>2,375,576</p></td><td><p>0</p></td><td><p>9.88 days</p></td></tr><tr><td><p>Request to Delete</p></td><td><p>6,367,692</p></td><td><p>6,367,692</p></td><td><p>0</p></td><td><p>15.5 days</p></td></tr><tr><td><p>Request to Correct*</p></td><td><p>38</p></td><td><p>32</p></td><td><p>6</p></td><td><p>13.84 days</p></td></tr><tr><td><p>Request to Opt-Out of Data Sharing for Tailored Ads</p></td><td><p>78,145,777</p></td><td><p>78,145,777</p></td><td><p>0</p></td><td><p>1 day</p></td></tr></tbody></table>
1302|
1303**Type of request**
14061304
1305 |
1306
1307**Received**
1308
1309 |
1310
1311**Complied**
1312
1313 |
1314
1315**Denied**
1316
1317 |
1318
1319**Average response rate**
1320
1321 |
1322| --- | --- | --- | --- | --- |
1323|
1324
1325Right to Know / Access
1326
1327 |
1328
13292,375,576
1330
1331 |
1332
13332,375,576
1334
1335 |
1336
13370
1338
1339 |
1340
13419.88 days
1342
1343 |
1344|
1345
1346Request to Delete
1347
1348 |
1349
13506,367,692
1351
1352 |
1353
13546,367,692
1355
1356 |
1357
13580
1359
1360 |
1361
136215.5 days
1363
1364 |
1365|
1366
1367Request to Correct\*
1368
1369 |
1370
137138
1372
1373 |
1374
137532
1376
1377 |
1378
13796
1380
1381 |
1382
138313.84 days
1384
1385 |
1386|
1387
1388Request to Opt-Out of Data Sharing for Tailored Ads
1389
1390 |
1391
139278,145,777
1393
1394 |
1395
139678,145,777
1397
1398 |
1399
14000
1401
1402 |
1403
14041 day
1405
1406 |
1407
14071408\*Adjustments in the user account within the Service made either by the user themselves or aided by customer services are not counted as correction requests (e.g., user updated their display name)
14081409
1409## [11\. Changes to this Policy]()
1410## **11\. Changes to this Policy**
14101411
14111412We may occasionally make changes to this Policy.
14121413
14131414When 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.
14141415
1415## [12\. How to contact us]()
1416
14171416For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:
14181417
14191418- email [privacy@spotify.com](mailto:privacy@spotify.com)
14201419- write to us at: Spotify USA Inc., 150 Greenwich Street, Floor 62, New York, NY 10007, USA
14211420
14221421Spotify USA Inc. is the data controller of personal data processed under this Policy.