Provision record
Spotify · Spotify Privacy Policy · View original document ↗

Pseudonymized Data Sharing with Rightsholders

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Document Record

What it is

Generated by a model from the captured document; not read by a person

The policy discloses that Spotify shares pseudonymized user listening data with rightsholders, such as music labels and publishers, under contractual agreements, where data is identified by a code rather than directly identifying information.

ⓘ

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)

Generated by a model from the captured document; not read by a person

This provision establishes a contractually obligated data sharing relationship with third-party rightsholders that users cannot opt out of, as it is framed as necessary for Spotify to fulfill agreements with content owners. Pseudonymization reduces but does not eliminate re-identification risk depending on the data fields shared.

If You Do Nothing

⚠ Pseudonymized listening data will continue to be shared with rightsholders as a contractual obligation as described in the policy terms

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
To fulfill contractual obligations with third parties. For example, when we provide pseudonymized data about our users' listening because we have an agreement with a Spotify rightsholder to do so. Pseudonymized data means that your data is identified by a code rather than your name or other directly identifying information.

Excerpt from Spotify's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • FTC
    The FTC holds authority over accuracy of privacy disclosures including characterizations of data sharing arrangements with third parties
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Provision details

Document information
Document
Spotify Privacy Policy
Entity
Spotify
Date stated by the document
July 1, 2026
As printed in Spotify’s text (version CA-V-007554), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
March 6, 2026
Text quoted from version
CA-V-007554, captured Oct. 16, 2026
Document ID
CA-D-000036
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-007554)
da37ca0430bb3c08a9a71eed868dcfbaeb91bee556ad70518a471ce0d159958b
Analysis generated
October 16, 2026 02:15 UTC
Methodology
Evidence
Excerpt not yet checked against a stored version
Citation Record
Entity: Spotify
Document: Spotify Privacy Policy
Version: CA-V-007554
Captured: 2026-10-16 00:10:49 UTC
SHA-256: da37ca0430bb3c08…
URL: https://conductatlas.com/platform/spotify/spotify-privacy-policy/pseudonymized-data-sharing-with-rightsholders/
Accessed: Oct. 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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Frequently Asked Questions

What does Spotify's Pseudonymized Data Sharing with Rightsholders clause do?

This provision establishes a contractually obligated data sharing relationship with third-party rightsholders that users cannot opt out of, as it is framed as necessary for Spotify to fulfill agreements with content owners. Pseudonymization reduces but does not eliminate re-identification risk depending on the data fields shared.

Is ConductAtlas affiliated with Spotify?

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