Spotify turns off targeted advertising for younger users by default, but automatically turns it on when they reach a certain age with only an in-app notification.
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
The provision operationalizes age-based advertising differentiation, requiring notification when advertising status changes and providing a designated interface for preference modification. This establishes the procedural mechanism for transitioning users from restricted to standard advertising when age eligibility thresholds are met.
When a younger Spotify user reaches the age threshold for targeted advertising, Spotify automatically enables it and sends only an in-app notification — there is no active opt-in consent step, meaning the user must proactively opt out to avoid being profiled for advertising.
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"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 Account Privacy page where you can change your preferences or 'opt-out' of tailored advertising at any time under Tailored Ads.— Excerpt from Spotify's Spotify Privacy Policy
1) REGULATORY FRAMEWORK: This provision implicates COPPA (15 U.S.C. §6501; 16 C.F.R. Part 312) for users under 13, which requires verifiable parental consent before collecting personal information for advertising; CPRA §1798.121 and the California Age-Appropriate Design Code (AB 2273) which require privacy by default for users under 18 and restrict profiling of minors for advertising; FTC Act Section 5; Virginia VCDPA §59.1-578(B)(5) and similar state law provisions restricting processing of known minors' data for targeted advertising. The FTC and CPPA are primary enforcement authorities. FTC COPPA penalties reach $51,744 per violation per day. 2)
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The provision operationalizes age-based advertising differentiation, requiring notification when advertising status changes and providing a designated interface for preference modification. This establishes the procedural mechanism for transitioning users from restricted to standard advertising when age eligibility thresholds are met.
When a younger Spotify user reaches the age threshold for targeted advertising, Spotify automatically enables it and sends only an in-app notification — there is no active opt-in consent step, meaning the user must proactively opt out to avoid being profiled for advertising.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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