Anchor Privacy Policy

Effective as of March 8, 2023

  1. About This Policy
  2. Your rights and your preferences: Giving you choice and control
  3. Personal data we collect about you
  4. Our purpose for using your personal data
  5. Sharing your personal data
  6. Data retention and deletion
  7. Transfer to other countries
  8. Keeping your personal data safe
  9. Children
  10. Changes to this Policy
  11. How to contact us

"Any reference in this Policy to “Anchor” or the “Anchor Service” is a reference to the hosted experience of Spotify for Podcasters"

1. About This Policy

This Policy describes how we process your data when you use Anchor, a service provided by Spotify.

It applies to your use of Anchor ("Anchor" or "Anchor Service") and any recordings, audio, transcript, or other material that is made available through Anchor. References to "Spotify", "we", "us", or "our" are to the legal entity indicated at Section 11 "How to contact us"

From time to time, we may develop new or offer additional services. They'll also be subject to this Policy, unless stated otherwise when we introduce them.

This Policy is not...

  • the Anchor Terms of Service. That's a separate document, outlining the legal contract between you and Spotify for using the Anchor Service. It also describes the rules of the Anchor Service and your user rights.
  • about your use of other services provided by Spotify which have their own dedicated privacy policy, such as Spotify, Soundtrap, and Megaphone.

However, the Spotify Privacy Policy may also apply if you choose to link your Anchor account with your Spotify account to unlock certain additional functionalities.

2. Your rights and your preferences: Giving you choice and control

Privacy laws, including the General Data Protection Regulation ("GDPR"), give rights to individuals over their personal data.

See your rights and their descriptions in this table.

 It's your right to...
AccessBe informed of the personal data we process about you and to request access to it
RectificationRequest that we amend or update your personal data where it’s inaccurate or incomplete
ErasureRequest that we delete certain of your personal data
RestrictionRequest that we temporarily or permanently stop processing all or some of your personal data
Object

Object to us processing your personal data at any time, on grounds relating to your particular situation

Object to your personal data being processed for direct marketing purposes

Data portabilityRequest a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service
Not be subject to automated decision-makingNot be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

If you would like to exercise any of these rights, you can contact us at [email protected]. If you would like to change your push notification preferences, you can use the notification settings on your mobile device. Email marketing messages also include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send you).

You also have the right to contact the Swedish Authority for Privacy Protection or your local data protection authority about any questions or concerns.

If you are a resident of the state of California, after January 1,2020, please see our supplemental policy "Additional California Privacy Disclosures" which will discuss additional privacy rights you may have under applicable law regarding the processing of your personal data.

3. Personal data we collect from you

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

Collected when you sign up for the Anchor Service or when you update your account
CategoriesDescription
User Data

Personal data that we need to create your Anchor account and enables you to use the Anchor Service. The type of data collected depends on if you use third party services to sign in. This may include:

  • name
  • email address
  • password
  • date of birth
  • country

We receive some of this data from you, e.g. from the sign up form or account page. We also collect some of this data from your device e.g. country. For more information about how we collect country, see "Your general (non-precise) location".

You also have the option to provide us other information about yourself, such as:

  • website
  • social media handles

Collected through your use of the Anchor Service
CategoriesDescription
Usage Data

Personal data collected about you when you’re accessing and/or using the Anchor Service. There are a few types of information this includes, detailed in the following sections.

Information about how you use Anchor

Examples include:

  • your actions with the Anchor Service (including data and time) such as:
    • features you use
    • actions you take
    • account settings
    • your use of third party services, and applications in connection with the Anchor Service.
  • content you create, post, upload, and/or share using the Anchor Service.

Your technical data

Examples include:

  • URL information
  • online identifiers such as cookie data and IP addresses
  • information about the devices you use such as
    • device IDs
    • networks connection type (e.g. Wi-Fi, 4G, LTE, Bluetooth)
    • provider
    • network and device performance
    • browser type
    • language
    • operating system

Your general (non-precise) location

This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency).


Additional data you may choose to give us
CategoriesDescription
Payment and Purchase Data

If you are a listener and choose to support a creator, we collect your name and email address. Our payment processor collects your payment information.

If you are a creator, monetizing your content on the Anchor Service, we will collect and process personal data for the purposes of providing you payouts and administrating your tax reports.

This may include:

  • legal name
  • business name
  • home address
  • phone number
  • social security number
  • tax identification number

Our payment partner also collects your bank account information.

Contest, Surveys, and Sweepstakes DataWhen you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstakes, we collect the personal data you provide.

Collected from other ('third party') sources
CategoriesDescription
Authentication partnersIf you register for or log into the Anchor Service, using another service, we’ll receive your information from them to help create your account with us.
Third party applications and services you connect to your Anchor account

If you connect your Anchor account to a third party application and/or service, we may collect certain information from them to make the integration possible.

We’ll ask for your permission before we collect your information from certain third parties.

Technical service partnersWe work with technical service partners that give us certain data, such as mapping IP addresses to non-precise location data (e.g. city, state).

4. Our purpose for using your personal data

The table below sets out:

  • our purpose of processing your personal data
  • our legal justifications (each called a "legal basis") under data protection law, for each purpose
  • categories of personal data which we use for each purpose (see more about these categories in Section 3 'Personal data we collect about you').

Here is a general explanation of each "legal basis" to help you understand the table:

  • Performance of a Contract: When it’s necessary for Spotify (or a third party) to process your personal data to:
    • comply with obligations under a contract with you, e.g. Spotify’s obligations under the Terms of Use to provide the Anchor Service to you
    • or verify information before a new contract with you begins.
  • Legitimate Interest: When Spotify (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Anchor users. For example, using your Usage Data to improve the Anchor Service for all users. Contact us if you want to understand a specific justification.
  • Consent: When Spotify asks you to actively indicate your agreement to its use of your personal data for a certain purpose(s).
  • Compliance with Legal Obligations: When Spotify must process your personal data to comply with a law.

Purpose for processing your dataLegal BasisCategories of personal data used for the purpose

To provide the Anchor Service in accordance with the contract with you.

For example, when we use your personal data to:

  • set up an account for you
  • provide the Anchor app when you download it onto your device
Performance of a Contract
  • User Data
  • Usage Data
  • Payment and Purchase Data

To provide further parts of the Anchor Service.

For example, when we use your personal data to enable additional features.

Legitimate Interest

Our legitimate interests here include:

  • keeping the Anchor Service running and functional
  • allowing users to access and use the Anchor Service
  • User Data
  • Usage Data
  • Payment and Purchase Data
To diagnose, troubleshoot, and fix issues with the Anchor Service.Performance of a Contract
  • User Data
  • Usage Data

To evaluate and develop new features, technologies, and improvements to the Anchor Service.

For example, we analyse how our users react to a particular new feature and see whether we should make any changes.

Legitimate Interest

Our legitimate interests here include developing and improving products and features for our users.

  • User Data
  • Usage Data
  • Contests, Surveys and Sweepstakes Data

For marketing or advertising where the law requires us to collect your consent.

For example, when we use cookies to understand your interests or the law requires consent for email marketing.

Consent

  • User Data
  • Usage Data
  • Contests, Surveys and Sweepstakes Data
For other marketing, promotion and advertising purposes where the law does not require consent.

Legitimate Interest

Our legitimate interests here include marketing and promoting the Anchor Service.

  • User Data
  • Usage Data
  • Contests, Surveys and Sweepstakes Data

To comply with legal obligations that we are subject to.

This might be:

  • an obligation under the law of the country / region you are in
  • Swedish law (because of our headquarters in Sweden), or
  • EU law that applies to us

For example, when we use your date of birth when required for age verification purposes.

Compliance with legal obligations
  • User Data
  • Usage Data
  • Payment and Purchase Data
  • Contests, Surveys and Sweepstakes Data
To comply with a request from law enforcement, courts, or other competent authorities.

Compliance with legal obligations, and legitimate interest

Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.

  • User Data
  • Usage Data
  • Payment and Purchase Data
  • Contests, Surveys and Sweepstakes Data
To fulfill contractual obligations with third parties.

Legitimate interest

Our legitimate interests here include maintaining our relationships with other third parties so we can provide the Anchor Service.

  • User Data
  • Usage Data
  • Payment and Purchase Data
To take appropriate action with reports of intellectual property infringement and inappropriate content.

Legitimate interest

Our legitimate interests here include protecting intellectual property and original content.

  • User Data
  • Usage Data
  • Payment and Purchase Data

To establish, exercise, or defend legal claims.

For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.

Legitimate interest

Our legitimate interests here include:

  • seeking legal advice
  • protecting ourselves, our users or others in legal proceedings
  • User Data
  • Usage Data
  • Payment and Purchase Data
  • Contests, Surveys and Sweepstakes Data

To conduct business planning, reporting, and forecasting.

For example, when we look at aggregated user data, like the number of new sign ups in a country, in order to plan new locations to launch our products and features in.

Legitimate interest

Our legitimate interests here include researching and planning so that we can keep running our business successfully.

  • User Data
  • Usage Data
  • Payment and Purchase Data
To process and administer payments.Performance of a Contract, and consent
  • User Data
  • Payment and Purchase Data

To keep the Anchor Service secure and to detect and prevent fraud.

For example, when we analyse Usage Data to check for fraudulent use of the Spotify Service.

Legitimate Interest

Our legitimate interests here include protecting the Anchor Service and our users against fraud and other illegal activity.

  • User Data
  • Usage Data
  • Payment and Purchase Data

To conduct research, and surveys.

For example, when we contact our users to ask for your feedback.

Legitimate Interest

  • Consent

    Our legitimate interests here include to understand more about how users think about and use the Anchor Service.

    • User Data
    • Usage Data
    • Contests, Surveys and Sweepstakes Data

    5. Sharing your personal data

    This section sets out the categories of recipients of the personal data collected or generated through your use of the Anchor Service.

    Publicly available information

    The following personal data will always be publicly available on the Anchor Service:

    • public posts and/or content that are immediately delivered via RSS feeds and/or our APIs to our partners and other third parties, including search engines, developers, and publishers that integrate the Services content into their services

    Personal data you may choose to share

    We will only share the following personal data with those outlines in the table below:

    • where sharing of particular personal data is needed for the use of an Anchor Service feature, or a third party application or service, which you have chosen to use; or
    • if you otherwise grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Spotify Service or by giving your consent

    Categories of recipientsReason for sharing
    Third party applications, and services you connect to your Anchor AccountTo connect your Anchor account, and/or allow you to use the Anchor Service in connection with third party applications, or services.

    Information we may share

    See this table for details of who we share to and why.

    Categories of recipientsReason for sharing
    Service Providers

    So they can provide their services to Spotify, to facilitate the Anchor Service.

    These service providers may include those we hire to:

    • give customer support
    • operate the technical infrastructure we need to provide the Anchor Service
    • assist in protecting and securing our systems and services
    • help market Spotify’s (and our partners’) products, services, events and promotions
    Payment partnersSo they can process your payment and/or our payouts, and for anti-fraud purposes.
    Marketing Partners

    To promote Anchor with our partners. We share some personal data with these partners where necessary to:

    • enable you to participate in Anchor promotions
    • to promote Anchor in media and advertising published on other online services
    • to help us and our partners to measure the effectiveness of Anchor promotions

    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 service). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you.

    Other Spotify group companiesWhere we have offices, to carry out our daily business operations and so we can maintain and provide the Anchor Service 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 businessWhere we sell or negotiate to sell our business to a buyer or possible buyer. In this situation, your personal data may be transferred to a successor or affiliate as part of that transaction along with other assets. Spotify will continue to ensure your personal data is kept confidential.

    6. Data retention and deletion

    Retention

    We keep your personal data only as long as necessary to provide you with the Anchor Service and for legitimate and essential business purposes, such as

    • maintaining the performance of the Anchor Service
    • making data-driven business decisions about new features and offering
    • complying with our legal obligations
    • resolving disputes.

    Deletion

    If you close or request that we close your account, we’ll delete or anonymise your personal data so it no longer identifies you, unless we’re required to keep something or we still need to use it for a legally justifiable reason.

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

    • if there’s an unresolved issue relation to your account, such as an outstanding credit or unresolved claim or dispute
    • for our legal, tax, audit and accounting obligations
    • for our legitimate business interests such as fraud prevention or to maintain security

    7. Transfer to other countries

    When carrying out the activities described in this Policy, Spotify shares your personal data internationally with other Spotify group companies, subcontractors and partners. They may process your personal data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

    Whenever we transfer personal data internationally, we use tools to:

    • make sure the data transfer complies with applicable law
    • help to give your data the same level of protection as it has in the EU

    We do this using a variety of protections, as appropriate for each data transfer. For example, we use:

    • Standard Contractual Clauses (or an alternative legal tool) to require the third party to protect your data and to provide you with EU-level rights and protections
    • technical protections, such as encryption and pseudonymisation
    • policies and processes to challenge disproportionate or unlawful government authority requests

    You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.

    8. Keeping your personal data safe

    We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

    We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

    To protect your user account, we encourage you to:

    • use a strong password that is unique to your Anchor account
    • never share your password with anyone
    • limit access to your computer or browser
    • log out once you have finished using the Anchor Service on a shared device

    9. Children

    The Anchor Service has a minimum “Age Limit” in each country. The Anchor Service is not directed to children whose age:

    • is under the age or 13 years
    • or, makes it illegal to process their personal data
    • or, requires parental consent to process their personal data

    We do not knowingly collect personal data from children under the applicable Age Limit. If you’re under the Age Limit, please do not use the Anchor Service, and do not provide any personal data to us.

    If you’re a parent of a child under the Age Limit and become aware that your child has provided personal data to Spotify via the Anchor Service, please contact us.

    If we learn that we’ve collected the personal data of a child under the applicable Age Limit, we’ll take reasonable steps to delete the personal data. This may require us to delete the Anchor account for that child.

    10. Changes to this Policy

    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. For example, we may display a prominent notice within the Anchor Service or send you an email or device notification.

    11. How to contact us

    For any questions or concerns about this Policy, please contact our Data Protection Officer by emailing [email protected] or by writing to your relevant data controller at the address below.

    Data controller if you reside in the US:

    Spotify USA, Inc.150 Greenwich StNew York, NY 10007USA

    Data controller if you reside in any other country than the US:

    Spotify ABRegeringsgatan 19111 53 StockholmSweden