Effective as of 30 October 2019
2 About this Policy
3 Parental controls and security
4 How do we collect your child’s personal data?
5 What personal data do we collect from you and your child?
6 What do we use your child’s personal data for?
7 Sharing your child’s personal data
8 Data retention and deletion
9 Transfer to other countries
11 How to contact us
Thanks for using our new app developed for children, that we call “Spotify Kids”!
At Spotify, we want to give you and your child the best possible experience to ensure that you enjoy Spotify Kids. In particular, the privacy and security of your and your child’s personal data is, and will always be, enormously important to us.
This Policy sets out the essential privacy details relating to Spotify Kids. The terms governing Spotify Kids are defined in our Family Terms and Conditions of Use. The aim of this Policy is 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.
We hope this Policy helps you understand our privacy commitment to you and your child. For further clarification of the terms used in this Policy please visit our Privacy Center on spotify.com. For information on how to contact us if you ever have any questions or concerns, please see How to contact us below.
We are committed to protecting the privacy of your child’s personal data. We have implemented appropriate technical and organisational measures to help protect the security of your child’s personal data; however, please note 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.
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. If you have concerns around our processing of your child’s personal data, we hope you will continue to work with us to resolve them. However, you can also contact and have the right to lodge a complaint to the Swedish Data Protection Authority (Datainspektionen) or your local Data Protection Authority.
When you and your child use Spotify Kids, we collect your personal data in the following ways:
- When you create a Spotiy Kids account – when you create a Spotify Kids account, we collect certain personal data so your child can enjoy Spotify Kids, including chosen name and, optionally, birthdate. You are also able to choose e.g. an avatar and a color to personalize your child’s Spotify Kids account. In addition, we collect the country you provided in your Spotify account.
- Through the use of Spotify Kids – when you and your child use Spotify Kids, we collect personal data about your use of Spotify Kids, such as what songs you have played and what songs you have saved as favorites.
We have set out in the tables below the categories of personal data we collect and use about you and your child:
Personal data collected when you create a Spotify Kids account
|Categories of personal data||Description of category|
|User Data||This is the personal data that is provided by you or collected by us to enable you to sign up your child and use Spotify Kids. This includes the chosen name, and birthdate. You will also be able to choose e.g. a color and an avatar for your child’s Spotify Kids account. In addition, we use the country you provided in your Spotify account.
Some of the personal data we will ask you to provide is required in order to create your child’s Spotify Kids account, such as chosen 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.
Personal data collected through the use of Spotify Kids
|Categories of personal data||Description of category|
|Usage Data||This is the personal data that is collected about you and your child when you are using Spotify Kids. This may include:
We have set out in the table below the reasons why we process your and your child’s personal data, the associated legal bases we rely upon to legally permit us to process your and your child’s personal data, and the categories of personal data (identified in What personal data do we collect from you and your child?) used for these purposes:
|Description of why Spotify processes your and your child’s personal data (“processing purpose”)||Legal basis for the processing purpose||Categories of personal data used by Spotify for the processing purpose|
|To provide, personalize, and improve your and your child’s experience with Spotify Kids, for example by providing customized, personalized, or localized content, recommendations, and features.||
|To understand how you and your child access and use Spotify Kids, to ensure technical functionality of Spotify Kids, develop new products and services, and to analyze your and your child’s use of Spotify Kids, including your and your child’s interaction with products, and services that are made available, linked to, or offered through the Spotify Service.||
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 11 How to contact us for further details on how to contact us.
We have set out the categories of recipients of the personal data collected or generated through your and your child’s use of Spotify Kids.
Information we share with your permission
|Categories of Recipients||Reason for sharing|
|Third Party Applications you connect to the Spotify Kids account||If you connect the Spotify Kids account to a Third Party Application, for example, audio, television, or automotive platforms, we may share User Data and Usage Data, as defined above, so you can connect the Spotify Kids account. We will not share any personal data without first obtaining your permission.|
Other information we may share
|Categories of Recipients||Reason for sharing|
|Service Providers and Others||We use technical service providers which may operate the technical infrastructure that we need to provide Spotify Kids, in particular providers which host, store, manage, and maintain the Spotify application, its content and the data we process.|
|Other Spotify Group Companies||We will share your and your child’s personal data with other Spotify Group companies to carry out our daily business operations and to enable us to maintain and provide Spotify Kids to you and your child.|
|Law Enforcement and Data Protection Authorities||We will share your and your child’s personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.
We will also share your and your child’s personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your and/or your child’s interests or fundamental rights and freedoms requiring the protection of your and/or your child’s personal data.
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 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, and resolving disputes. We keep some of your and your child’s personal data for as long as you are a user of Spotify Kids, for example, saved songs, and account information.
If you request, we will delete or anonymise your and your child’s personal data so that it no longer identifies you or your child, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
- If there is an unresolved issue relating to your and/or your child’s account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by sending you an email. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
111 53 Stockholm
We hope you enjoy Spotify Kids!
© Spotify AB.