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Privacy Evaluation for Spotify Music

Last updated September 7, 2022

Overview

Spotify is a digital music service that gives users access to millions of songs. The terms of Spotify state that the product allows for social interaction between users and publicly displays personal information as a part of its interactive service. The terms say that personal information is shared with third parties for marketing, business, and other logistical purposes; much of the marketing purposes include displaying tailored content and advertisements for both third party advertisers and Spotify. The policies say that Spotify implements multiple security measures to prevent data breaches, but the policies do not say whether a user will be notified in the event of a breach. Lastly, the terms make it clear that Spotify is not a product intended for children under the age of 13.

Spotify can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Spotify’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Privacy Center, Additional California Privacy Disclosures, and Cookies Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms of Spotify state they provide personalized services with social and interactive features. Spotify users may post, upload, or otherwise contribute content, which may include, for example, pictures, text, messages, information, playlist titles, descriptions and compilations, and/or other types of content. The terms state that the following personal data will always be publicly available on Spotify: a user's name and/or username, profile picture, who they follow and who follows them on Spotify, their recently played artists, and their public playlists. The terms state that shared or publicly available information may be used and re-shared by other users on Spotify or across the web, so users should use Spotify carefully and be mindful of their privacy account settings.

Privacy

Spotify's terms state that the service can collect personal data such as a user's email address, birth date, gender, postal code, and country, as well as voice data. Through the use of Spotify the service may collect a user's personal data such as what songs they have played and what playlists they have created. The terms state users can ask to share personal data (like their email address) with artists or record labels, or other partners who may want to directly send users news or promotional offers, but a user can also revoke that consent at any time. In addition, the terms state Spotify may share personal data with certain marketing and advertising partners to send users promotional communications about Spotify. The terms state Spotify may also share personal data in a pseudonymized format with marketing partners who help Spotify with promotional efforts and with advertisers that allow them to offer a free service.

The terms also state Spotify receives personal data about a user and their activity from third parties, including advertisers and partners they work with in order to provide targeted advertisements on the Spotify service. Lastly, Spotify may allow their business partners to use cookies or other similar technologies on or outside the Spotify service for collecting information about a user's online activities over time and across different websites, applications, and/or devices.

Security

The terms of Spotify state they take reasonable steps to protect the confidentiality and security of personal information collected from users of the service. Spotify's terms state they implement appropriate technical and organizational measures to help protect the security of users' personal data. In addition, they have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in their systems. However, the terms do not disclose whether users are notified in the event of a data breach.

Compliance

Spotify's terms state that in order to use the Spotify service a user must be 18 years or older, or be 13 years or older and have a parent or guardian’s consent. The terms state that if Spotify learns that they have collected the personal data of a child under the age of 13, then they will take reasonable steps to delete the personal data. This may require Spotify to delete the account for that child. Lastly, the terms state Spotify provides users the ability to access, review, modify, delete, and export their personal information from the service at any time.

Data Collection
SCORE: 35%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Geolocation data are collected.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • Unclear whether this product collects sensitive data.
  • Data is automatically collected.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 70%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • Unclear whether the categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
  • Third-party login is supported.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 45%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • Unclear whether third-parties with access to information are required to provide the same security protections as the company.
  • Reasonable security practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • All data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 75%

What rights do I have to the data?

  • Users can create or upload content.
  • Users retain ownership of their data.
  • Processes to access or review user data are available.
  • Processes to modify data are available for authorized users.
  • A data-retention policy is available.
  • Processes for authorized users to delete data are available.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Unclear whether methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 30%

Is the data sold?

  • Personal information is not sold or rented to third parties.
  • Users can opt out from the disclosure or sale of their data to a third party.
  • User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
  • Unclear whether users are notified if their information is transferred to a third party.
  • Unclear whether user information can be deleted prior to its transfer to a third party.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • Unclear whether user information that is shared is shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 30%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
  • Personal information can be displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed to others.
  • User-created content is not reviewed, screened, or monitored by the company.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 60%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • Personalised advertising is displayed.
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for personalised advertisements.
  • The company can send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 50%

Can I provide parental consent?

  • Not intended for children under 13.
  • Personal information from children under 13 years of age is not collected.
  • Unclear whether intended for parents or guardians.
  • Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
  • The company does provide a section, heading, or separate policy for children in their policies.
  • Unclear whether parental consent is required before personal information is collected or disclosed.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Parents can withdraw consent for the further collection of their child's information.
  • Children's personal information is deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 0%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Processes to enter education records into the product are not described.
  • Unclear whether additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 25%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Unclear whether use of information is limited to the purpose for which it was collected.
  • The context or purpose for which data are collected is indicated.
  • Company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Unclear whether notice is provided if the context in which data are collected changes.
  • Unclear whether consent is obtained if the practices in which data are collected change.
  • Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
  • Unclear whether users can request to know what personal information has been shared with third parties.
  • Unclear whether notice is provided in the event the company receives a government or legal request for a user's information.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.