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.
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.
How other platforms handle this
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Automatically switching younger users to targeted advertising when they age into eligibility — with only an in-app notification — may not provide adequate notice or meaningful consent, particularly for users who are still minors in some legal frameworks.
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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