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.

Overall Score

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 ScoreFull Score
Comprehensive Assessment5654

Concerns

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.

ConcernBasic ScoreFull Score
Data Collection: Protecting personal information2555
Data Sharing: Protecting data from third parties7580
Data Security: Protecting against unauthorized access5045
Data Rights: Controlling rights to data8895
Data Sold: Preventing sale of data7555
Data Safety: Promoting responsible use3835
Ads & Tracking: Prohibiting the exploitation of users' decision making process5060
Parental Consent: Protecting children’s personal information6750
School Purpose: Following student data privacy laws00

Statutes

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.

StatuteBasic ScoreFull Score
California Online Privacy Protection Act (CalOPPA)7573
Children's Online Privacy Protection Act (COPPA)5957
Family Educational Rights and Privacy Act (FERPA)5644
Student Online Personal Information Protection Act (SOPIPA)5459
General Data Protection Regulation (GDPR)6462

Privacy Policy Details

1: Transparency

1.1: Policy Version
  • Privacy policies do indicate a version or effective date.
  • Privacy policies do not indicate a changelog 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
  • 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: Policy Contact
  • Users can contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
  • Privacy policies do indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
  • Privacy policies are available in multiple languages.
1.8: Intended Use
  • Not intended for children under 13.
  • 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 not collected.
  • Biometric or health data are collected.
  • Behavioral data are collected.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Unclear whether free or reduced lunch status is 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 online.
2.3: Data Exclusion
  • Specific types of personal information are not collected.
  • Unclear whether specific types of collected information are excluded from the privacy policy.
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.
  • Data are shared for third-party advertising and/or 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
  • Data are not sold or rented to third parties.
3.5: Third-Party Data Acquisition
  • Personal information from users is acquired from third parties.
3.6: Third-Party Links
  • Links to third-party external websites are not age-appropriate.
3.7: Third-Party Data Access
  • 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 if found to be misused.
3.10: Third-Party Service Providers
  • Data are shared with third-party service providers.
  • The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
  • The categories of third parties that receive personal information are indicated.
3.12: Third-Party Policies
  • Links to privacy policies of third-party companies are not available.
3.13: Third-Party Data Combination
  • Unclear whether data can be combined with data from third-party sources.
  • Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
  • Social or federated login is supported.
  • Personal information from social or federated login providers is collected.
  • Personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
  • User information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification 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 deidentified information.

4: Respect for Context

4.1: Data Use
  • Use of information is limited to the purpose for which it was collected.
  • The purpose for which data atr collected is indicated.
4.2: Data Combination
  • Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
  • 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
  • Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
  • A grievance or remedy mechanism is not available for users to file a complaint.
5.4: Data Settings
  • Users can control 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 for commercial purposes.
  • Unclear whether notice is provided in the event the vendor 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 not limited in scope or duration.
  • Unclear whether notice is provided to users when their content is removed or disabled because of an alleged copyright violation.

6: Access and Accuracy

6.1: Data Access
  • Processes to access and review user data are available.
  • Permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to review data are available for the school, parents, or students.
6.2: Data Integrity
  • The vendor does not maintain the accuracy of data they collect.
6.3: Data Correction
  • Processes to modify inaccurate data are available.
  • Unclear whether the school, parents, or students can modify data.
  • Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
  • A data-retention policy is available.
  • The retention time period of a user's data can be changed upon a valid inspection request.
6.5: Data Deletion
  • Data are deleted when no longer necessary.
  • A user's data are deleted upon account cancellation or termination.
  • Processes to delete user data are available.
  • Processes for the school, parents, or students to delete data are available.
  • Unclear whether the time period for the vendor 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.
  • Notice is provided to users if the vendor assigns its rights or delegates its duties to another company.
  • Users are not 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
  • Third-party transfer is contractually required to use the same privacy practices.

8: Security

8.1: User Identity
  • A user's identity is verified with additional personal information.
8.2: User Account
  • Account creation is required.
  • Unclear whether parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
8.3: Third-Party Security
  • Unclear whether third-party contractual security protections are required.
8.4: Data Confidentiality
  • Industry best practices are used to protect data.
  • Employee or physical access to user information is limited.
8.5: Data Transmission
  • All data in transit are encrypted.
8.6: Data Storage
  • Unclear whether this product encrypts all data at rest.
  • Personal information of users is not stored with a third party.
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 security-compliance audits.

9: Responsible Use

9.1: Social Interactions
  • Users can interact with trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
9.2: Data Visibility
  • Personal information is displayed publicly.
  • Users can control how their data are displayed.
9.3: Monitor and Review
  • Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
  • 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.
9.4: Report Content
  • Unclear whether users can filter or block inappropriate content.
  • Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
  • Unclear whether the vendor provides links to tools or processes that support safe and appropriate social interactions.

10: Advertising

10.1: Vendor Communications
  • A user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
  • Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
  • Behavioral or targeted advertising is displayed.
10.4: Ad Tracking
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
  • Children may receive inappropriate advertisements.
10.6: Marketing Communications
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
  • Unclear whether this product responds to Do Not Track or other opt-out mechanisms.
  • The vendor does provide a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • Vendor does not have actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product restricts account creation for users under 13 years of age.
  • Unclear whether this product restricts in-app purchases for users under 13 years of age.
  • Unclear whether the vendor participates in an FTC-approved COPPA safe harbor program.
11.2: Students in K–12
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor as a school official.
11.3: Parental Consent
  • Parental consent is required.
  • 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.
  • Unclear whether the vendor can use collected information to support the “internal operations” of the product.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.
  • 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 any dispute 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 vendor will disclose personal information to law enforcement.
11.5: Certification
  • Unclear whether the vendor 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, such as the GDPR.
  • The vendor has indicated it is a Data Controller or Data Processor.