Spotify Kids Privacy Policy

Effective as of 1 September 2021

About this Policy
Parental controls and security
Personal data we collect about you and your child
Our purpose for using your personal data
Sharing your child's personal data
Data retention and deletion
Transfer to other countries
Changes to this Privacy Policy
How to contact us

1. About this Policy

This Policy describes how we process your and your child's personal data when using Spotify Kids. The aim of this Policy is to explain how Spotify gives your child a great experience when using Spotify Kids, and in particular to:

Ensure that you understand what personal data we collect about you and your child when using Spotify Kids, the reasons why we collect and use it, and who we share it with;
Explain the additional privacy and security measures and controls we have implemented for Spotify Kids in order to provide a good environment for your child; and
Explain the available rights and choices in relation to the personal data we collect and process about you and your child when using Spotify Kids, and how we will protect the privacy of your child.

This information can also be found in our Kids resource, designed to be understood by the older children using Spotify Kids.

The Spotify® Premium for Family Terms and Conditions is a separate document outlining the legal contract between you and Spotify for using the Spotify Premium Family Plan, including Spotify Kids.

2. Parental controls and security

We are committed to protecting your and your child's personal data. We implement appropriate technical and organisational measures to help protect the security of your child's personal data; however, be aware that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

To help ensure a good environment for your child when using Spotify Kids, we've also implemented the following controls:

Parental protection - in order to access and enable certain functions in Spotify Kids, such as creating or deleting a child's account and changing the account settings, you as a parent need to provide a verification code. This allows you to control what features your child may use on Spotify Kids and prevents your child from changing settings by themselves.
Appropriate content - Spotify Kids will only contain age-appropriate content, selected by our editors. At account setup, you will have the option to select what kind of content your child's Spotify Kids account should contain.

In the Spotify Privacy Policy you can learn more about the rights and preferences applicable to any of your personal data which is processed by Spotify. You can, at any time, access the personal data associated with the Spotify Kids account. In addition, you can always request that we delete the personal data associated with the Spotify Kids account. If you request deletion of your own Spotify account, the personal data associated with the Spotify Kids account will automatically be deleted.

If you have any questions about your child's privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the "Contact Us" form on the Privacy Center. We will respond to your request within a reasonable period of time upon verification of your identity. You also have the right to contact the Swedish Authority for Privacy Protection or your local data protection authority about any questions or concerns.

3. Personal data we collect about you and your child

These tables set out the categories of personal data we collect and use.

Collected when you sign up for the Spotify Kids Service or when you update your account
Categories of personal data	Description of category
User Data	Personal data that we need to create your Spotify Kids account and which enables you and your child to use Spotify Kids. This includes your child’s name. You also have the option to provide us with your child’s birthdate and select a color and an avatar in order to make your child’s Spotify Kids account more personalized. In addition, we use the country you provided in your Spotify account.

Collected through your use of the Spotify Kids Service

Categories of personal data

Description of category

Usage Data

Personal data collected about you and your child when you’re accessing and/or using Spotify Kids:

Information about how you use Spotify Kids including your actions with Spotify Kids, such as date and time of content you have listened to or saved, search queries, and account settings.
Your technical data, for example:
- URL information,
- IP addresses,
- information about devices you use such as: device IDs, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Spotify application version.
Your general (non-precise) location. This is understood from technical data (e.g. your IP address or language setting of your device) and is needed to meet geographic requirements in our agreements with owners of content on Spotify Kids.

Collected from third party sources
Categories of personal data	Description of category
Third party applications and devices you connect to your Spotify Kids account	If you connect your Spotify Kids account to a third party application and/or device(s), we may collect certain information from them to make the integration possible. We will only collect personal data from these third parties when you as a parent allow us to do so, e.g. by selecting the appropriate setting, allowing bluetooth connection on the device, and/or by providing your consent.
Technical service partners	We work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g., city, state, or post code). This makes it possible for us to provide Spotify Kids content and features.

4. Our purpose for using your personal data

The table below sets out:

our purpose for processing your personal data
our legal justifications (each called "legal basis") under data protection law, for each purpose
categories of personal data which are used for each purpose (these categories are defined in Section 3 "Personal data we collect about you and your child")

In Section 4 in the Spotify Privacy Policy we provide a general explanation of each legal basis to help you understand the table.

Purpose for processing your data	Legal basis that permits the purpose	Legal basis that permits the purpose
Purpose for processing your data	Legal basis that permits the purpose	Categories of personal data used for the purpose
To provide Spotify Kids to you and your child, including basic content recommendations based on for example; age group, country, and time of day. For example, if you have a young child and it is night time, we might position lullabies and bedtime content more prominently in the app for you.	Performance of a Contract Legitimate Interest	User Data Usage Data
To understand, diagnose, troubleshoot, and fix issues with Spotify Kids.	Performance of a Contract Legitimate Interest	User Data Usage Data
To evaluate and develop new features, technologies, and improvements to Spotify Kids.	Legitimate Interest	User Data Usage Data
To market Spotify Kids, and send offers, promotions, recommendations, and surveys to you as a parent.	Legitimate Interest Consent	User Data Usage Data
To comply with legal obligations, law enforcement requests, and fulfill contractual obligations with third parties, such as rights holders.	Compliance with legal obligations Legitimate Interest	User Data Usage Data
To establish, exercise, or defend legal claims.	Legitimate Interest	User Data Usage Data
To conduct business planning, reporting, and forecasting.	Legitimate Interest	User Data Usage Data
To detect fraud, including fraudulent use of Spotify Kids.	Performance of a Contract Compliance with legal obligations Legitimate Interest	User Data Usage Data

If you require further information about the balancing test that Spotify has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 9 'How to contact us' for further details on how to contact us.

5. Sharing your child's personal data

This section sets out the categories of recipients of the personal data collected or generated through your and your child's use of Spotify Kids.

Personal data you may choose to share

Categories of Recipients	Reason for sharing
Third party applications and devices you connect to the Spotify Kids account	We work with trusted third parties to enable certain features and functionalities on Spotify Kids that you choose to use, such as listening on Spotify Kids through your home speaker. We will only share personal data with these third parties when you as a parent allow us to do so, e.g. by selecting the appropriate setting, allowing bluetooth connection on the device, and/or by providing your consent. If you do allow us to do so in that way, we will only share personal data required to enable that integration such as username/identifier.

Categories of Recipients

Reason for sharing

Third party applications and devices you connect to the Spotify Kids account

We work with trusted third parties to enable certain features and functionalities on Spotify Kids that you choose to use, such as listening on Spotify Kids through your home speaker. We will only share personal data with these third parties when you as a parent allow us to do so, e.g. by selecting the appropriate setting, allowing bluetooth connection on the device, and/or by providing your consent. If you do allow us to do so in that way, we will only share personal data required to enable that integration such as username/identifier.

Information we may share

Categories of Recipients	Reason for sharing
Service providers	So they can provide their services to Spotify. These service providers may include those we hire to: give customer support operate the technical infrastructure we need to provide Spotify Kids help market products, services, events, and promotions.
Other Spotify Group Companies	Where we have offices, to carry out our daily business operations and so we can maintain and provide Spotify Kids to you.
Law enforcement and other authorities	When we believe in good faith it’s necessary for us to do so, for example: to comply with a legal obligation to respond to a valid legal process (such as a search warrant, court order, or subpoena) for our own or a third party’s justifiable interest, relating to: national security law enforcement litigation (a court case) criminal investigation protecting someone’s safety preventing death or imminent bodily harm.
Purchasers of our business	Where we sell or negotiate to sell our business to a buyer or possible buyer. In this situation, Spotify will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

6. Data retention and deletion

Retention

We keep your and your child's personal data only as long as necessary to provide you and your child with Spotify Kids and for Spotify's legitimate and essential business purposes, such as:

maintaining the performance of Spotify Kids
making data-driven business decisions about new features and offerings
complying with our legal obligations
resolving disputes.

Deletion

If you close or request that we close your account, we will delete or anonymise your and your child's personal data so that it no longer identifies you, unless, we are legally allowed or required to keep something.

Here are some examples of situations where we're legally allowed or required to keep some of your personal data:

if there is an unresolved issue relating to your Spotify Kids account(s), such as an unresolved claim or dispute
for our legal, tax, audit, and accounting obligations
for our legitimate business interests such as fraud prevention or to maintain the security of our users.

use of privacy contact form
email privacy@spotify.com
write to us at: Spotify USA Inc., 150 Greenwich Street, Floor 62, New York, NY 10007, USA

Spotify USA Inc. is the data controller of personal data processed under this Policy.

We hope you enjoy Spotify Kids!