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124 changes: 124 additions & 0 deletions products/spotify.toml
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name = "Spotify"
description = "Spotify is a Sweden-based music and podcast streaming platform offering free and premium streaming, recommendations, and social features."
slug = "spotify"
hostnames = ["spotify.com"]
sources = [
"https://www.spotify.com/de-en/legal/privacy-policy/",
"https://www.spotify.com/de-en/account/privacy/"
]
contributors = ["Anon-sec"]

[rubric.behavioral-marketing]
value = "yes-opt-out"
citations = [
"Control the tailored ads you see and hear on Spotify.",
"The toggle below controls the tailored ads you experience on Spotify's services, as well as Spotify's ads targeted to you on other platforms.",
"If tailored ads are turned off: We will not share your information with third party advertising partners for the purposes of tailored advertising",
"If tailored ads are turned off: We will not share your information with other platforms to market Spotify promotions, features, or new releases on those other platforms"
]
notes = [
"The Account Privacy page provides a toggle to disable tailored advertising. Turning it off also stops sharing with third-party advertising partners and other platforms. Non-tailored ads may still be shown."
]

[rubric.data-breaches]
value = "no"
citations = []
notes = [
"The privacy policy does not state that Spotify notifies users of data breaches or commits to a breach-notification process."
]

[rubric.data-collection-reasoning]
value = "yes"
citations = [
"The table below sets out: our purpose for processing your personal data; our legal justifications (each called a “legal basis”) under data protection law."
]
notes = [
"Spotify includes a table explaining purposes and legal bases such as Performance of a Contract, Consent, Legal Obligation, and Legitimate Interest."
]

[rubric.data-deletion]
value = "yes-contact"
citations = [
"Request that we erase certain of your personal data.",
"To request erasure of your other personal data from Spotify, follow the steps on our support page."
]
notes = [
"Full data erasure requires submitting a request; it is not fully automated."
]

[rubric.history]
value = "last-modified"
citations = [
"Effective as of 27 August 2025"
]
notes = [
"Only an effective date is given; no change history is provided."
]

[rubric.law-enforcement]
value = "reasonable"
citations = [
"To comply with a request from law enforcement, courts, or other competent and authorized third parties.",
"to respond to a valid legal process (such as a search warrant, court order, or subpoena)"
]
notes = [
"Policy allows disclosure when legally required or in response to valid legal processes. It also allows disclosure under good faith justifications."
]

[rubric.list-collected]
value = "generally"
citations = [
"These tables set out the categories of personal data we collect from you.",
"Personal data that we need to create your Spotify account and that enables you to use the Spotify Service."
]
notes = [
"Lists are structured but use language such as 'may include', meaning they are examples rather than exhaustive lists."
]

[rubric.noncritical-purposes]
value = "opt-out-some"
citations = [
"Control the tailored ads you see and hear on Spotify.",
"If tailored ads are turned off, the content of ads we show you will not be based on: Your use of Spotify over time; Your interests obtained from 3rd party advertising partners."
]
notes = [
"Users can disable tailored advertising, but some non-essential purposes such as analytics and service improvements cannot be disabled."
]

[rubric.revision-notify]
value = "yes"
citations = [
"When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances."
]
notes = [
"Spotify commits to notifying users when material changes occur."
]

[rubric.security]
value = "yes"
citations = [
"We put in place appropriate technical and organisational measures to help protect the security of your personal data."
]
notes = [
"Security measures are described, but audits or certifications are not mentioned."
]

[rubric.third-party-access]
value = "yes-unspecified"
citations = [
"If tailored ads are turned off: We will not share your information with third party advertising partners for the purposes of tailored advertising",
"Our partners may also combine the personal data we share with them with other data they collect about you, e.g. your use of their services."
]
notes = [
"Spotify names categories of recipients but does not provide a full list of specific companies who receive user data."
]

[rubric.third-party-collection]
value = "yes"
citations = [
"If you connect your Spotify account to a third party application, service or device, we may collect and use information from them.",
"If you choose to pay through third parties (e.g. telco carriers) or by invoice, we may get data from our payment partners."
]
notes = [
"Spotify receives personal data from connected third-party services, payment providers, and integrated platforms."
]
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