Privacy Policy
20240801_rev01 · COMPARED WITH 20240701_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE
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| 1 | Your privacy is important. As of 27 June, we've updated our Privacy Policy to make it easier to read and include additional detail. | |
| 2 | ||
| 3 | 1 | Effective as of 27 June 2024 |
| 4 | 2 | |
| 5 | [1\. About this Policy]() | |
| 3 | ## **1\. About this Policy** | |
| 6 | 4 | |
| 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 | ||
| 31 | 5 | This Privacy Policy describes how we process your personal data at Spotify USA Inc. From now on, we'll call it the 'Policy'. |
| 32 | 6 | |
| 33 | 7 | It applies to your use of: |
| 34 | 8 | |
| 35 | 9 | - all Spotify streaming services as a user. For example this includes: |
| 36 | 10 | - your use of Spotify on any device |
| 62 | 36 | - choose whether to show your recently played artists on your public profile |
| 63 | 37 | |
| 64 | 38 | On the 'Explicit Content' setting you can control whether explicit-rated content can be played on your Spotify account. |
| 65 | 39 | |
| 66 | 40 | - [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. |
| 67 | 41 | |
| 68 | ## [2\. Your personal data rights and controls]() | |
| 42 | ## **2\. Your personal data rights and controls** | |
| 69 | 43 | |
| 70 | 44 | Privacy laws give certain rights to individuals over their personal data. |
| 71 | 45 | |
| 72 | 46 | The table below explains: |
| 73 | 47 | |
| 74 | 48 | - your rights |
| 95 | 69 | **Be informed of the personal data we process about you and how we process it.** |
| 96 | 70 | |
| 97 | 71 | | |
| 98 | 72 | |
| 99 | 73 | We inform you: |
| 100 | 74 | |
| 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]() | |
| 102 | 78 | |
| 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 | ||
| 107 | 79 | | |
| 108 | 80 | | |
| 109 | 81 | |
| 110 | 82 | **Know/** |
| 111 | 83 | |
| 112 | 84 | **Access** |
| 116 | 88 | **Request to know and access the personal data we process about you.** |
| 117 | 89 | |
| 118 | 90 | | |
| 119 | 91 | |
| 120 | 92 | To request a copy of your personal data from Spotify, either: |
| 121 | 93 | |
| 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]() | |
| 123 | 96 | |
| 124 | • [contact us]() | |
| 125 | ||
| 126 | 97 | 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](). |
| 127 | 98 | |
| 128 | 99 | | |
| 129 | 100 | | |
| 130 | 101 | |
| 131 | 102 | **Correction** |
| 146 | 117 | | |
| 147 | 118 | |
| 148 | 119 | **Request that we delete certain of your personal data.** |
| 149 | 120 | |
| 150 | 121 | Please note there are situations where Spotify is unable to delete your data, for example when: |
| 151 | 122 | |
| 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 | |
| 153 | 127 | |
| 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 | ||
| 160 | 128 | | |
| 161 | 129 | |
| 162 | 130 | There are several ways you can delete personal data from Spotify: |
| 163 | 131 | |
| 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/) | |
| 165 | 135 | |
| 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 | ||
| 170 | 136 | | |
| 171 | 137 | | |
| 172 | 138 | |
| 173 | 139 | **Opt-out of tailored advertising** |
| 174 | 140 | |
| 175 | 141 | | |
| 244 | 210 | 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. |
| 245 | 211 | |
| 246 | 212 | **Appeals process** |
| 247 | 213 | |
| 248 | 214 | 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. |
| 249 | 215 | |
| 250 | #### [Tailored advertising controls]() | |
| 216 | #### **Tailored advertising controls** | |
| 251 | 217 | |
| 252 | 218 | What is tailored advertising? |
| 253 | 219 | |
| 254 | 220 | - 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. |
| 255 | 221 | - 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. |
| 256 | 222 | |
| 264 | 230 | If 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. |
| 265 | 231 | |
| 266 | 232 | Appropriate age for tailored advertising: |
| 267 | 233 | |
| 268 | 234 | - 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. |
| 269 | 235 | |
| 270 | ## [3\. Personal data we collect about you]() | |
| 236 | ## **3\. Personal data we collect about you** | |
| 271 | 237 | |
| 272 | 238 | 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). |
| 273 | 239 | |
| 274 | 240 | | |
| 275 | 241 | **Collected when you sign up for the Spotify Service** |
| 276 | 242 | |
| 304 | 270 | | |
| 305 | 271 | |
| 306 | 272 | Personal data that we need to create your Spotify account and that enables you to use the Spotify Service. |
| 307 | 273 | |
| 308 | 274 | 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: |
| 309 | 275 | |
| 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) | |
| 311 | 285 | |
| 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 | ||
| 328 | 286 | We receive some of this data from you e.g. from the sign up form or account page. |
| 329 | 287 | |
| 330 | 288 | 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. |
| 331 | 289 | |
| 332 | 290 | | |
| 333 | 291 | | |
| 339 | 297 | Geolocation data |
| 340 | 298 | |
| 341 | 299 | | |
| 342 | 300 | |
| 343 | 301 | We may ask for and process your street address for the following reasons: |
| 344 | 302 | |
| 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 | |
| 346 | 308 | |
| 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 | ||
| 355 | 309 | In some cases, we may use a third party application to help you verify your address, such as Google Maps. |
| 356 | 310 | |
| 357 | 311 | | |
| 358 | 312 | |
| 359 | 313 | | |
| 360 | 314 | **Collected through your use of the Spotify Service** |
| 395 | 349 | There are a few types of information this includes, listed in the following sections. |
| 396 | 350 | |
| 397 | 351 | **Information about how you use Spotify** |
| 398 | 352 | |
| 399 | 353 | Examples include: |
| 400 | 354 | |
| 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 | |
| 402 | 368 | |
| 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 | ||
| 427 | 369 | **Your technical data** |
| 428 | 370 | |
| 429 | 371 | Examples include: |
| 430 | 372 | |
| 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 | |
| 432 | 389 | |
| 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 | ||
| 463 | 390 | **Your general (non-precise) location** |
| 464 | 391 | |
| 465 | 392 | 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. |
| 466 | 393 | |
| 467 | 394 | We need this to: |
| 468 | 395 | |
| 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 | |
| 470 | 398 | |
| 471 | • deliver content and advertising that's relevant to you | |
| 472 | ||
| 473 | 399 | **Your device sensor data** |
| 474 | 400 | |
| 475 | 401 | 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. |
| 476 | 402 | |
| 477 | 403 | | |
| 478 | 404 | |
| 505 | 431 | | |
| 506 | 432 | |
| 507 | 433 | 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. |
| 508 | 434 | |
| 509 | 435 | The exact personal data collected and used will vary depending on the payment method. It will include information such as: |
| 510 | 436 | |
| 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 | |
| 512 | 444 | |
| 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 | |
| 518 | Note: 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 | ||
| 526 | 445 | | |
| 527 | 446 | | |
| 528 | 447 | |
| 529 | 448 | Survey and Research Data |
| 530 | 449 | |
| 531 | 450 | | |
| 580 | 499 | | |
| 581 | 500 | |
| 582 | 501 | 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. |
| 583 | 502 | |
| 584 | 503 | These third party apps, services or devices may include: |
| 585 | 504 | |
| 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 | |
| 587 | 514 | |
| 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 | ||
| 604 | 515 | We'll ask your permission before we collect your information from certain third parties. |
| 605 | 516 | |
| 606 | 517 | | |
| 607 | 518 | |
| 608 | 519 | User Data |
| 609 | 520 | |
| 636 | 547 | | |
| 637 | 548 | |
| 638 | 549 | If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners. |
| 639 | 550 | |
| 640 | 551 | This allows us to: |
| 641 | 552 | |
| 642 | • send you invoices | |
| 553 | - send you invoices | |
| 554 | - process your payment | |
| 555 | - give you what you've purchased | |
| 643 | 556 | |
| 644 | • process your payment | |
| 645 | ||
| 646 | • give you what you've purchased | |
| 647 | ||
| 648 | 557 | 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. |
| 649 | 558 | |
| 650 | 559 | Receiving this data allows us to: |
| 651 | 560 | |
| 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 | |
| 653 | 564 | |
| 654 | • analyze the effectiveness of our partnership with these merchant partners | |
| 655 | ||
| 656 | • understand your interests | |
| 657 | ||
| 658 | 565 | | |
| 659 | 566 | |
| 660 | 567 | Payment and Purchase Data |
| 661 | 568 | |
| 662 | 569 | | |
| 663 | 570 | | |
| 690 | 597 | Usage Data |
| 691 | 598 | |
| 692 | 599 | | |
| 693 | 600 | |
| 694 | 601 | 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. |
| 695 | 602 | |
| 696 | ## [4\. Our purpose for using your personal data]() | |
| 603 | ## **4\. Our purpose for using your personal data** | |
| 697 | 604 | |
| 698 | 605 | The table below sets out: |
| 699 | 606 | |
| 700 | 607 | - our purpose for processing your personal data |
| 701 | 608 | - categories of personal data which we use for each purpose. See more about these categories in [Section 3 'Personal data we collect about you']() |
| 702 | 609 | |
| 703 | You can also watch our video about [Personal Data at Spotify](https://www.spotify.com/privacy). | |
| 704 | ||
| 705 | 610 | | |
| 706 | 611 | **Purpose for processing your data** |
| 707 | 612 | |
| 708 | 613 | | |
| 709 | 614 | |
| 710 | 615 | **Categories of personal data used for the purpose** |
| 948 | 853 | • Usage Data |
| 949 | 854 | |
| 950 | 855 | • Survey and Research Data |
| 951 | 856 | |
| 952 | 857 | | |
| 953 | 858 | |
| 954 | ## [5\. Disclosing your personal data]() | |
| 859 | ## **5\. Disclosing your personal data** | |
| 955 | 860 | |
| 956 | 861 | This section sets out who receives personal data which is collected or generated through your use of the Spotify Service. |
| 957 | 862 | |
| 958 | 863 | **Publicly available information** |
| 959 | 864 | |
| 960 | 865 | The following personal data will always be publicly available on the Spotify Service (except to any user you have blocked): |
| 1269 | 1174 | • Usage Data |
| 1270 | 1175 | |
| 1271 | 1176 | | |
| 1272 | 1177 | |
| 1273 | 1178 | When we believe in good faith it's necessary for us to do so, for example: |
| 1274 | 1179 | |
| 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 | |
| 1276 | 1189 | |
| 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 | ||
| 1293 | 1190 | | |
| 1294 | 1191 | | |
| 1295 | 1192 | |
| 1296 | 1193 | Purchasers of our business |
| 1297 | 1194 | |
| 1298 | 1195 | | |
| 1312 | 1209 | If we were to sell or negotiate to sell our business to a buyer or possible buyer. |
| 1313 | 1210 | |
| 1314 | 1211 | In this case, we may transfer your personal data to a successor or affiliate as part of that transaction. |
| 1315 | 1212 | |
| 1316 | 1213 | | |
| 1317 | 1214 | |
| 1318 | ## [6\. Data retention]() | |
| 1215 | ## **6\. Data retention** | |
| 1319 | 1216 | |
| 1320 | 1217 | 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: |
| 1321 | 1218 | |
| 1322 | 1219 | - maintaining the performance of the Spotify Service |
| 1323 | 1220 | - making data-driven business decisions about new features and offerings |
| 1324 | 1221 | - complying with our legal obligations |
| 1325 | 1222 | - resolving disputes |
| 1326 | 1223 | |
| 1327 | 1224 | Here are some of the categories of our retention periods, and the criteria we use to determine them: |
| 1328 | 1225 | |
| 1329 | - \*_Data retained until you remove it_ | |
| 1226 | - **Data retained until you remove it** | |
| 1330 | 1227 | |
| 1331 | 1228 | 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, and the circumstances in which we can act on your request. |
| 1332 | 1229 | |
| 1333 | 1230 | You 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. |
| 1334 | 1231 | |
| 1335 | - \*_Data that expires after a specific period of time_ | |
| 1232 | - **Data that expires after a specific period of time** | |
| 1336 | 1233 | |
| 1337 | 1234 | We 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. |
| 1338 | 1235 | |
| 1339 | - \*_Data retained until your Spotify account is deleted_ | |
| 1236 | - **Data retained until your Spotify account is deleted** | |
| 1340 | 1237 | |
| 1341 | 1238 | We 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. |
| 1342 | 1239 | |
| 1343 | - \*_Data retained for extended time periods for limited purposes_ | |
| 1240 | - **Data retained for extended time periods for limited purposes** | |
| 1344 | 1241 | |
| 1345 | 1242 | After 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: |
| 1346 | 1243 | |
| 1347 | 1244 | - to help ensure user safety, or |
| 1348 | 1245 | - to protect against harmful content on our platform. |
| 1349 | 1246 | |
| 1350 | 1247 | 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/). On the other hand, we will remove unlawful content if the law requires us to do so. |
| 1351 | 1248 | |
| 1352 | ## [7\. Transfer to other countries]() | |
| 1249 | ## **7\. Transfer to other countries** | |
| 1353 | 1250 | |
| 1354 | 1251 | Because 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. |
| 1355 | 1252 | |
| 1356 | 1253 | Whenever we transfer personal data internationally, we use tools to make sure the data transfer complies with applicable law. |
| 1357 | 1254 | |
| 1358 | 1255 | We also identify and use additional protections as appropriate for each data transfer. For example, we use: |
| 1359 | 1256 | |
| 1360 | 1257 | - technical protections, such as encryption and pseudonymization |
| 1361 | 1258 | - policies and processes to challenge disproportionate or unlawful government authority requests |
| 1362 | 1259 | |
| 1363 | ## [8\. Keeping your personal data safe]() | |
| 1260 | ## **8\. Keeping your personal data safe** | |
| 1364 | 1261 | |
| 1365 | 1262 | 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. |
| 1366 | 1263 | |
| 1367 | 1264 | 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. |
| 1368 | 1265 | |
| 1369 | 1266 | To protect your user account, we encourage you to: |
| 1377 | 1274 | 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). |
| 1378 | 1275 | |
| 1379 | 1276 | 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. |
| 1380 | 1277 | |
| 1381 | 1278 | 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. |
| 1382 | 1279 | |
| 1383 | ## [9\. Children]() | |
| 1280 | ## **9\. Children** | |
| 1384 | 1281 | |
| 1385 | 1282 | Note: 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. |
| 1386 | 1283 | |
| 1387 | 1284 | The Spotify Service has a minimum 'Age Limit' in each country or region. The Spotify Service is not directed to children whose age: |
| 1388 | 1285 | |
| 1389 | 1286 | - is under the age of 13 years |
| 1395 | 1292 | 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](). |
| 1396 | 1293 | |
| 1397 | 1294 | 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. |
| 1398 | 1295 | |
| 1399 | 1296 | 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. |
| 1400 | 1297 | |
| 1401 | ## [10\. Privacy Request Metrics]() | |
| 1298 | ## **10\. Privacy Request Metrics** | |
| 1402 | 1299 | |
| 1403 | 1300 | The following chart contains statistics about global requests we received from users between 1 January and 31 December 2023: |
| 1404 | 1301 | |
| 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** | |
| 1406 | 1304 | |
| 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 | ||
| 1325 | Right to Know / Access | |
| 1326 | ||
| 1327 | | | |
| 1328 | ||
| 1329 | 2,375,576 | |
| 1330 | ||
| 1331 | | | |
| 1332 | ||
| 1333 | 2,375,576 | |
| 1334 | ||
| 1335 | | | |
| 1336 | ||
| 1337 | 0 | |
| 1338 | ||
| 1339 | | | |
| 1340 | ||
| 1341 | 9.88 days | |
| 1342 | ||
| 1343 | | | |
| 1344 | | | |
| 1345 | ||
| 1346 | Request to Delete | |
| 1347 | ||
| 1348 | | | |
| 1349 | ||
| 1350 | 6,367,692 | |
| 1351 | ||
| 1352 | | | |
| 1353 | ||
| 1354 | 6,367,692 | |
| 1355 | ||
| 1356 | | | |
| 1357 | ||
| 1358 | 0 | |
| 1359 | ||
| 1360 | | | |
| 1361 | ||
| 1362 | 15.5 days | |
| 1363 | ||
| 1364 | | | |
| 1365 | | | |
| 1366 | ||
| 1367 | Request to Correct\* | |
| 1368 | ||
| 1369 | | | |
| 1370 | ||
| 1371 | 38 | |
| 1372 | ||
| 1373 | | | |
| 1374 | ||
| 1375 | 32 | |
| 1376 | ||
| 1377 | | | |
| 1378 | ||
| 1379 | 6 | |
| 1380 | ||
| 1381 | | | |
| 1382 | ||
| 1383 | 13.84 days | |
| 1384 | ||
| 1385 | | | |
| 1386 | | | |
| 1387 | ||
| 1388 | Request to Opt-Out of Data Sharing for Tailored Ads | |
| 1389 | ||
| 1390 | | | |
| 1391 | ||
| 1392 | 78,145,777 | |
| 1393 | ||
| 1394 | | | |
| 1395 | ||
| 1396 | 78,145,777 | |
| 1397 | ||
| 1398 | | | |
| 1399 | ||
| 1400 | 0 | |
| 1401 | ||
| 1402 | | | |
| 1403 | ||
| 1404 | 1 day | |
| 1405 | ||
| 1406 | | | |
| 1407 | ||
| 1407 | 1408 | \*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) |
| 1408 | 1409 | |
| 1409 | ## [11\. Changes to this Policy]() | |
| 1410 | ## **11\. Changes to this Policy** | |
| 1410 | 1411 | |
| 1411 | 1412 | We may occasionally make changes to this Policy. |
| 1412 | 1413 | |
| 1413 | 1414 | 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. |
| 1414 | 1415 | |
| 1415 | ## [12\. How to contact us]() | |
| 1416 | ||
| 1417 | 1416 | For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways: |
| 1418 | 1417 | |
| 1419 | 1418 | - email [privacy@spotify.com](mailto:privacy@spotify.com) |
| 1420 | 1419 | - write to us at: Spotify USA Inc., 150 Greenwich Street, Floor 62, New York, NY 10007, USA |
| 1421 | 1420 | |
| 1422 | 1421 | Spotify USA Inc. is the data controller of personal data processed under this Policy. |