Spotify · Spotify Privacy Policy · View original document ↗

Children and Minors Data Handling

Medium severity Medium confidence Explicitdocumentlanguage Rare · 1 of 325 platforms
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This analysis describes what Spotify's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The automatic enablement of targeted advertising at a system-determined age transition, rather than requiring affirmative opt-in from the newly eligible user, may raise questions about adequate consent for advertising data use for young adults transitioning from minor to adult status.

Interpretive note: The specific age threshold at which tailored advertising is automatically enabled is not stated in the policy text reviewed, creating uncertainty about whether the transition point complies with California CAADCA and analogous state minors' privacy laws.

Consumer impact (what this means for users)

The policy states Spotify collects extensive usage data including search queries, streaming history, AI feature prompts and transcripts, device identifiers, and inferred interests, and authorizes sharing this data with advertising and analytics partners for tailored advertising on an opt-out basis. Spotify also discloses that facial photographs may be collected for age estimation by a third-party provider, though the policy states this Age Check Data is deleted immediately after verification. You can opt out of tailored advertising through the 'Tailored Ads' setting at spotify.com/account/privacy, and you can request a copy or deletion of your data through the 'Download your data' tool on the same page.

How other platforms handle this

Activision Medium

YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.

Google Gemini Medium

Our generative AI services are not directed at children. If you are under the applicable age of majority in your jurisdiction, you may only use these services with parental or guardian consent and supervision, subject to any additional restrictions set out in our family policies.

Replit Medium

Replit does not knowingly collect personal information from children under 13. Users between the ages of 13 and 18 may use the platform with parental or guardian consent. If we learn we have collected personal information from a child under 13 without verification of parental consent, we will delete...

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▸ View Original Clause Language DOCUMENT RECORD
"
Younger users may have tailored advertising turned off by default. When you reach the appropriate age, you will start to receive tailored advertising. When this happens, you will receive a message within the Spotify Service to let you know. This message will contain a link to the Tailored Ads setting where you can change your preferences or 'opt-out' of tailored advertising at any time.

— Excerpt from Spotify's Spotify Privacy Policy

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Spotify Privacy Policy
Entity
Spotify
Document last updated
May 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 12, 2026
Record ID
CA-P-007835
Document ID
CA-D-00036
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
62bfd0910e1d9815b6915626d36d1058b28aa407638be86ce562523eaf99f811
Analysis generated
April 28, 2026 08:47 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Spotify
Document: Spotify Privacy Policy
Record ID: CA-P-007835
Captured: 2026-04-28 08:47:36 UTC
SHA-256: 62bfd0910e1d9815…
URL: https://conductatlas.com/platform/spotify/spotify-privacy-policy/children-and-minors-data-handling/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Spotify's Children and Minors Data Handling clause do?

The automatic enablement of targeted advertising at a system-determined age transition, rather than requiring affirmative opt-in from the newly eligible user, may raise questions about adequate consent for advertising data use for young adults transitioning from minor to adult status.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.

Is ConductAtlas affiliated with Spotify?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Spotify.