Privacy Evaluation for Spotify: Music and podcasts

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Spotify is an online streaming service that provides digital access to listen to music and podcasts. Spotify's terms make clear the terms cover the Spotify service, and not the Spotify Kids service. The terms are also say that children may not use Spotify and should be directed to Spotify Kids. The terms for Spotify say that the service collects personal information from users and that some of the information collected will be visible on a user's public profile. Additionally, the terms say that Spotify uses and discloses the information collected from users to conduct targeted advertising on the platform and other services. Spotify's terms are also say that the service uses reasonable security measures to protect user data including the use of encryption. Lastly, the terms say that social interactions are possible on the service through user profiles and content but that Spotify is not responsible for moderating that content.

Spotify: Music and podcasts 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. Additionally, other policies used for this evaluation include: Cookie Policy and Supplemental U.S. State Privacy Notice. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.


Spotify's terms are clear that users have public profiles that may contain personal information, including listening history. They are also clear that users on the Spotify platform may interact with one another through their profiles. In addition, the terms are clear that information on profiles is visible to all other users of the service with the exception of anyone blocked by that user. Spotify's terms are also clear that users may upload content to the service and that Spotify is not obligated to review and monitor that content, but reserves the right to do so. The terms also make clear that users should be careful with the information and content made available to other users as they may use and share that information with others.


Spotify's terms say that the service may collect personal information from users including email address, phone number, date of birth, street address, and gender. Additionally, the terms are clear that Spotify will use tracking technologies to collect usage information about users while on the service. The terms also indicate that Spotify may use the data collected on the service to target advertising to users while on the service and track them on other sites and services for commercial purposes. Spotify's terms also indicate that the service may share the information collected about users with third party marketing partners who may use that information to deliver targeted advertising. The terms say that users may connect their Spotify account with accounts on other platforms, like social media. Connecting a Spotify account with a social media account allows users to share content from Spotify with the social media service, but also enables Spotify to collect personal information from the social media account. Spotify's terms indicate that the information collected from and shared with third party partners may be used to build advertising profiles to better serve targeted ads to users. In addition to the targeted ads delivered by Spotify, users may also be served with contextual ads while interacting with the service. The terms are clear that if a user opts out of having personal information used for targeted advertising, they will still be served contextual ads on Spotify.


Spotify's terms indicate that they take reasonable steps to protect the information collected from users of the service. They indicate that procedures and practices are in place to leverage pseudonymization, encryption, access, and retention policies to protect data. However, the terms are not clear which types personal information are protected by each measure nor when they are used. For example, the terms do not address whether the encryption may be limited to payment information or includes all personal information nor whether the data are encrypted in transit, at rest, or both. Further, the terms do not address how Spotify would respond in the event of a data breach nor how impacted users may be notified.


Spotify's terms are clear that users are given the right to access, modify, and request the deletion of their personal information. They clearly state that users may access and modify personal information through account settings and a data download tool on Spotify. They are also clear that Spotify has data retention policies that delete most personal information upon the user deletion of their account. However, Spotify may retain user data for certain purposes including to prevent harm to other users and protecting intellectual rights. The terms are not clear how long Spotify may retain data for these purposes.

The terms are clear that the Spotify service is not directed at children under the age of 13. They clearly indicate that guardians should notify Spotify if a child under 13 has provided personal information to the service. Spotify's terms state that they will take reasonable steps to remove the child's personal information from the service, which may include deleting the child's account. The terms do indicate that teens between the ages of 13 and 17 may use Spotify with the consent of a parent. However, they are not clear whether or how Spotify will obtain verifiable consent for users in that age group.


This product received a Warning rating based on the following details:
  • Unclear whether personal information is sold or rented to third parties.
  • Personal information is shared for third-party marketing.
  • 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.
Data Collection
SCORE: 60%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • 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.
  • Sensitive data are collected.
  • Data is automatically collected.
  • 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: 55%

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.
  • Employee or physical access to user information is limited.
  • 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: 85%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether 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.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • 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?

  • Unclear whether personal information is 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.
  • 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: 35%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • 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 reviewed, screened, or monitored by the company.
  • Unclear whether user-created content is 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: 40%

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.
  • Company does have actual knowledge that personal information from users under 13 years of age is collected.
  • The company does not 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.
  • Unclear whether this product allows parents to 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

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.