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.
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.
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 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.
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.
Every privacy rating includes an overall score. A higher score (up to 100%) means the product provides more transparent privacy policies with better practices to protect user data. The score is best used is as an indicator of how much additional work a person will need to do to make an informed decision about a product.
|Basic Score||Full Score|
The privacy evaluation process summarizes the policies of an application or service into concern categories based on a subset of evaluation questions that can be used to quickly identify particular practices of a vendor’s policies. These concerns are composed of evaluation questions that can be used to calculate scores relative to that concern.
|Concern||Basic Score||Full Score|
|Data Collection: Protecting personal information||50||35|
|Data Sharing: Protecting data from third parties||50||70|
|Data Security: Protecting against unauthorized access||67||45|
|Data Rights: Controlling rights to data||88||75|
|Data Sold: Preventing sale of data||75||30|
|Data Safety: Promoting responsible use||67||30|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||50||60|
|Parental Consent: Protecting children’s personal information||50||50|
|School Purpose: Following student data privacy laws||0||0|
|Individual Control: Controlling data use||NA||25|
Each statute or regulation is associated with one or more evaluation questions. As such, we can calculate scores for each statute or regulation using only those questions associated with the statute or regulation. Each specific statute or regulation's score serves as an indirect proxy indicating the likelihood of the application or service satisfying all of its compliance obligations.
|Statute||Basic Score||Full Score|
|California Online Privacy Protection Act (CalOPPA)||64||54|
|Children's Online Privacy Protection Act (COPPA)||60||50|
|Family Educational Rights and Privacy Act (FERPA)||38||27|
|Student Online Personal Information Protection Act (SOPIPA)||54||46|
|General Data Protection Regulation (GDPR)||60||46|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a change log or past policy version is available.
1.2: Policy Notice
- Users are notified if there are any material changes to the policies.
- Privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
- Unclear whether users are notified prior to any material changes to the policies.
- Changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Privacy Contact
1.6: Policy Principles
- Privacy policies do indicate privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are not available in multiple languages.
1.8: Intended Use
- Not intended for children under 13.
- Not intended for teens.
- Intended for adults over 18.
- Unclear whether intended for parents or guardians.
- Unclear whether intended for students.
- Unclear whether intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- 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.
2.2: Data Source
- Unclear whether personal information or education records are collected from preK-12 students.
- Personal information from children under 13 years of age is not collected.
2.3: Data Excluded
- Unclear whether specific types of personal information excluded from collection.
2.4: Data Limitation
- Unclear whether the collection or use of data is limited to product requirements.
3: Data Sharing
3.1: Data Shared With Third Parties
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
3.2: Data Use by Third Parties
- The purpose for sharing a user's personal information with third parties is indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Personal information is shared for third-party marketing.
3.3: Data Not Shared With Third Parties
- Unclear whether there are specific categories of information that are not shared with third parties.
3.4: Data Sold to Third Parties
- Personal information is not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information about users is obtained from third parties.
3.6: Third-Party Links
- Unclear whether links to third-party external websites are age-appropriate.
3.7: Third-Party Data Access
- Unclear whether third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
- Unclear whether personal information can be deleted from a third party.
3.10: Third-Party Service Providers
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- Unclear whether the categories of third parties that receive data are indicated.
3.12: Third-Party Policies
- Unclear whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Company may combine data with additional data from third-party sources.
- Data shared with third parties can be combined with other data.
3.14: Third-Party Authentication
- Third-party login is supported.
- Personal information from third-party login providers is collected.
- Personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
- 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.
3.16: Third-Party Contractual Obligations
- Unclear whether contractual limits are placed on third-party data use.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
4: Respect for Context
4.1: Data Use
- 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.
4.2: Data Combination
- Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
- Unclear whether notice is provided if the context in which data are collected changes.
4.4: Data Changes
- Unclear whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Users can create or upload content.
5.2: User Consent
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
- Users can control the use of their information through privacy settings.
5.5: Data Disclosure
- Users can opt out from the disclosure or sale of their data to a third party.
- 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.
5.6: Intellectual Property
- Users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Any copyright license to a user's data is limited in scope or duration.
6: Access and Accuracy
6.1: Data Access
- Processes to access or review user data are available.
- Unclear whether methods are available to restrict who has access to data.
- Unclear whether the school, parents, or students can review student data.
6.2: Data Integrity
- Unclear whether the company attempts to maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify data are available for authorized users.
- Unclear whether the school, parents, or students can modify inaccurate student information.
- Unclear whether the time period for the company to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Unclear whether exceptions to the data retention policy exist.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether a user can delete all their data.
- Processes for authorized users to delete data are available.
- Unclear whether the time period for the company to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- Unclear whether a user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Notice is provided to users if the company assigns its rights or delegates its duties to another company.
- Unclear whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Unclear whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
8.1: User Identity
- A user's identity is verified with additional personal information.
8.2: User Account
- Account creation is required.
- Unclear whether managed accounts are available.
- Unclear whether multi-factor account protection is available.
8.3: Third-Party Security
- Unclear whether third-parties with access to information are required to provide the same security protections as the company.
8.4: Data Confidentiality
- Reasonable security practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
8.5: Data Transmission
- All data in transit are encrypted.
8.6: Data Storage
- All data are stored in an encrypted format.
- The company is clear what jurisdiction a user's personal information is subject to.
8.7: Data Breach
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Unclear whether this product performs data-privacy and/or security-compliance audits.
9: Responsible Use
9.1: Social Interactions
- 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.
9.2: Data Visibility
- Personal information can be displayed publicly.
- Unclear whether this product allows users to control how their data are displayed to others.
9.3: Monitor and Review
- 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.
9.4: Report Content
- Users can filter or block inappropriate content.
- Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
- Unclear whether the company provides links to resources that support safe and appropriate social interactions.
10.1: Vendor Communications
- Unclear whether a user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
- Personalised advertising is displayed.
10.4: Ad Tracking
- 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.
10.5: Filtered Advertising
- Unclear whether ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- 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.
10.8: Do Not Track
- Company does respond to "Do Not Track" or other opt-out mechanisms.
- Unclear whether the company provides a method for users to opt-out from third-party tracking.
11.1: Children Under 13
- 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.
- Account creation is restricted or prohibited for users under 13 years of age.
11.2: Students in K–12
- 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.
11.3: Parental Consent
- 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.
- Unclear whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies is indicated.
- A user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- A user is required to waive the right to join a class action lawsuit.
- A company will disclose personal information to law enforcement.
- Unclear whether the company has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- A user's data are subject to International data transfer or jurisdiction laws.
- The company has indicated it is a Data Controller or Data Processor.