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Privacy Policy

Effective Date: January 1, 2023

Megaphone, a service offered by Spotify (“Megaphone,” “we,” or “us”). Megaphone is committed to treating the personal data we process with respect and sensitivity. We want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data. This Privacy Policy (“Policy”) aims to explain what we mean in further detail below.

1. About this Policy

This Policy sets out the essential details relating to our collection, use, and disclosure of personal data you use the website, Publisher Platform, Advertiser Services, and any other products and services that link to this Policy (collectively, the "Services"). 

In this policy we describe our personal data processing activities for the following types of data subjects: 

  • Publishers (“Publishers”) who use our publisher-facing product (the “Publisher Platform”) that helps publishers of podcasts monetize their podcasts by inserting ads into the podcasts hosted by Megaphone. Advertisers (“Advertisers”) who use our advertiser-facing services (the “Advertiser Services”) to help reach targeted audiences (“Advertiser Dashboard”).
  • Listeners (“Listeners”) of podcasts hosted by Megaphone, whether they are listening on Spotify or other third party audio streaming services. 

From time to time, we may develop new or offer additional services. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

This policy is not…

  • the Megaphone Terms of Service or Community Guidelines, which are separate documents.
  • About your use of other services offered by Podsights affiliates which have their own privacy policy, such as the Spotify service, Anchor, Megaphone, Soundtrap, and Spotify Live.

If you are a Listener, depending on the service on which you listen to podcasts (e.g., Spotify or another service), that service’s privacy policies may apply to you in addition to this Policy, which may contain additional disclosures and rights. 

2. Your Personal Data Rights and Controls

Rights

As provided by applicable privacy laws, you may have certain rights as individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:

It’s your right to...

Be informed

Be informed of the personal data we process about you and how we process it.

Access

Request access to the personal data we process about you.

Rectification

Request that we amend or update your personal data where it’s inaccurate or incomplete.

Erasure

Request that we erase certain personal data about you.

For example, you can ask us to erase personal data: 

that we no longer need for the purpose it was collected for

that we process based on the legal basis of consent, and you withdraw your consent

when you make a justified objection (see section ‘Object’ below) 

There are situations where we are unable to delete your data, for example when: 

it’s still necessary to process the data for the purpose we collected it for

Megaphone’s interest in using the data overrides your interest in having it deleted

Megaphone has a legal obligation to keep the data, or

Megaphone needs the data to establish, exercise or defend legal claims

Restriction

Request that we stop processing all or some of your personal data.  

You can do this if:

your personal data is inaccurate

our processing is unlawful

we do not need your information for a specific purpose, or

you object to our processing and we are assessing your objection request. See section ‘Object’ below

You can request that we stop this processing temporarily or permanently.

Object

Object to us processing your personal data.

You can do this if Spotify is processing your personal data on the legal basis of legitimate interests.

Data portability

Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.

You can request us to transmit your data when we are processing your personal data on the legal basis of consent or performance of contract. However Spotify will try to honour any request to the extent possible. 

Not be subject to automated decision making

Request a manual review of 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. 

We currently do not use automated decision-making.

Withdrawal of consent

Withdraw your consent to us collecting or using your personal data.

You can do this if Spotify is processing your personal data on the legal basis of consent.

Right to lodge a complaint

Contact your local data protection authority about any questions or concerns.

You can request to access, remove or update the personal data that you have provided to us in your application by contacting us (see section 12 “Contact Us”).

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). We may decline requests to exercise these rights where we are unable to authenticate you as the person to whom the data relates. We will not discriminate against you for exercising any of your rights.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

If your request is denied you may have the right to appeal the denial in accordance with the instructions provided to you when the denial was made.

CCPA rights request metrics

Between January 1 and December 31, 2021, we have not received any verifiable requests for access or deletion of data that we are the controllers of.

No Sales or Sensitive Data

We do not sell personal data and have taken substantial steps to identify and remediate any data sharing arrangements that could constitute us "selling" to third parties under the CCPA following our acquisition by Spotify. 

We also do not process any data that is sensitive or special category data as defined by applicable law.

3. Personal Data We Collect About You

If you are a Publisher, the following tables below describe the categories of personal data we collect about you and how we collect it.

Data you choose to provide to us:

Categories of Personal Data

Categories under CCPA

Description of Category

Publisher Account Data

Identifiers

This is the personal data that is provided by you to enable Megaphone’s customer support team to sign you up for a publisher account with us, including first and last name and email address. Additional users of a publisher account may be added by providing the personal data of intended new users, including their first and last name and email address. 

Additionally, once a publisher account is established your time zone is automatically (which you are free to change) so that we can adjust the reporting on performance of your content to the local (or your preferred) timezone.

Publisher Inquiry Data

Identifiers; and other information you share.

This is personal data that you provide when filling out and submitting our Publisher inquiry form.

Survey Data

Identifiers; and other information you share.

This is personal data that you provide when participating in surveys.

 

Data we collect through your use of the Publisher Platform:

Categories of Personal Data

Categories under CCPA

Description of Category

Publisher Usage Data

Internet or other electronic network activity information

This is the personal data that is collected about you when you’re accessing and/or using the Publisher Platform, including:

Technical Data - Information that your browser automatically sends whenever you use our platform. Technical Data includes your Internet Protocol (“IP”) address, user agent, and interactions with the platform, such as pages visited, times spent on pages, and actions performed on pages.

Cookie Data - Information from cookies stored on your device. Please see the “Cookies” section below to learn more about how we use cookies.

Publisher Payment and Purchase Data

Commercial information

We collect your billing information when you execute a contract with us for our services, and our payment processor collects your credit card information when you purchase our services with a credit card. 

If you are an Advertiser, the following tables below describe the categories of personal data we collect about you and how we collect it.

Data you choose to provide to us:

Categories of Personal Data

Categories under CCPA

Description of Category

Advertiser Account Data

Identifiers

This is the personal data that is provided by you through submission of an insertion order when you purchase services from us or you are enabled to use our services after speaking with us.  The personal data includes, first and last name, phone number and email address. 

This also includes personal data you provide when establishing an account for the Advertiser Dashboard, including your name and email address. 

If you are an Advertiser that works with an Advertising Agency that uses the Advertiser Dashboard, the Advertising Agency  may provide your data to the platform to keep track of the campaigns they are working on for you.

Advertiser Inquiry Data

Identifiers; and other information you share.

This is personal data that you provide when filling out and submitting our Advertiser inquiry form.

Survey Data

Identifiers; and other information you share.

This is personal data that you provide when participating in surveys.

 

Data we collect through your use of the Advertiser Services:

Categories of Personal Data

Description of Category

Advertiser Usage Data

Internet or other electronic network activity information

This is the personal data that is collected about you when you’re accessing and/or using the Advertiser Platform, including:

Technical Data - Information that your browser automatically sends whenever you use our platform. Technical Data includes your IP address, user agent, and interactions with the platform, such as pages visited.

Cookie Data - Information from cookies stored on your device. Please see the “Cookies” section below to learn more about how we use cookies.

Advertiser Payment and Purchase Data

Commercial information

Our payment processors collect your payment information such as your name, billing address, and payment method and/or credit card information when you purchase our services.

 

If you are a Listener, the following tables below describe the categories of personal data we collect about you and how we collect it. 

Data we collect related to your listening of podcasts:

Categories of Personal Data

Categories under CPRA

Description of Category

Listener Data

Internet or other electronic network activity information

When a listener plays a podcast hosted by Megaphone, we collect your IP address and user agent. 

When a listener plays a podcast not hosted by Megaphone but the podcast publisher wants to use Megaphone’s services, they provide us with your IP address and user agent.

Inference Data

Inferences

We obtain from Nielsen inferences drawn about your interests and preferences based on your online and offline activities. If you do not wish for Nielsen to provide us with your personal data, please see the section “Opt-Outs” below.

 

4. Purposes of Processing

If you are a Publisher or Advertiser, when you use or interact with our platforms and services, we use a variety of technologies to process the personal data we collect about you for various reasons. If you are a Listener, when you listen to a podcast hosted by Megaphone, we process the personal data we collect about you to provide you a more personalized ad experience. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 3) used for these purposes:

Description of why we process your personal data (“processing purpose”)

Legal basis for processing purpose

Categories of personal data used for the processing purpose

To provide and personalize the Services.

Performance of a contract

Publisher Account Data

Publisher Usage Data

Advertiser Account Data

Advertiser Usage Data

To understand, diagnose, troubleshoot, and fix issues with the Service.

Performance of a contract

Publisher Account Data

Publisher Inquiry Data

Publisher Usage Data

Advertiser Account Data

Advertiser Inquiry Data

Advertiser Usage Data

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

Legitimate interest

Publisher Account Data

Publisher Inquiry Data

Publisher Usage Data

Advertiser Account Data

Advertiser Inquiry Data

Advertiser Usage Data

Survey Data

For marketing, promotion, and advertising purposes (to our customers).

Legitimate interest

Publisher Account Data

Publisher Inquiry Data

Advertiser Account Data

Advertiser Inquiry Data

For marketing, promotion, and advertising purposes (to personalize Listener experience on their streaming services).

Legitimate interest

Listener Data

Inference Data

Survey Data

To comply with legal obligations and law enforcement.

Compliance with legal obligations

Legitimate interest

Publisher Account Data

Publisher Inquiry Data

Publisher Usage Data

Publisher Payment and Purchase Data

Advertiser Account Data

Advertiser Inquiry Data

Advertiser Usage Data

Advertiser Payment and Purchase data 

Listener Data

Inference Data

Survey Data

To fulfill contractual obligations with third parties.

Legitimate interest

Publisher Payment and Purchase Data

Advertiser Payment and Purchase data

Listener Data

Inference Data

To establish, exercise, or defend legal claims.

Legitimate interest

Publisher Account Data

Publisher Inquiry Data

Publisher Usage Data

Publisher Payment and Purchase Data

Advertiser Account Data

Advertiser Inquiry Data

Advertiser Usage Data

Advertiser Payment and Purchase data

Listener Data

Inference Data

Survey Data

To conduct business planning, reporting, and forecasting.

Legitimate interest

Publisher Inquiry Data

Publisher Payment and Purchase Data

Advertiser Inquiry Data

Advertiser Payment and Purchase data

To process your payment.

Performance of a Contract

Publisher Payment and Purchase Data

Advertiser Payment and Purchase data

To detect fraud, including fraudulent payments and fraudulent use of the Services.

Legitimate Interest

Publisher Account Data

Publisher Inquiry Data

Publisher Usage Data

Publisher Payment and Purchase Data

Advertiser Account Data

Advertiser Inquiry Data

Advertiser Usage Data

Advertiser Payment and Purchase data

Listener Data

To conduct research and surveys.

Legitimate Interest

Listener Data

Survey Data

5. Sharing of Information

With respect to personal data we are controllers of, we may share or disclose the  data under the following circumstances, or as otherwise described in this Policy:

  • Within the Spotify group of companies, including companies that Spotify acquires. To carry out our daily business operations and so we can maintain, improve and provide the Spotify Service and acquired companies’ services to you.
  • Service Providers. We may share your information with our agents and service providers that perform certain functions or services on our behalf, such as to host our Services, manage databases, facilitate payment or send communications for us. We have direct relationships with certain advertising, marketing and analytics services (including some of our measurement partners) who also are our service providers that help us collect and analyze personal data.
  • Content providers. We may share your information with content providers for activities such as listenership and content analysis, but only in a pseudonymised format.
  • In connection with a transfer of assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your personal data to one or more third parties as part of that transaction;
  • To comply with legal requirements. We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to a valid legal process, such as a search warrant, a court order, or a subpoena. We also will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
  • Other parties with your consent. We may share information about you with third parties when you consent to such sharing.

6. Cookies 

We or our third party partners may store some information on your device or device hard drive as a "cookie" or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of these services and for the purpose of facilitating and enhancing your communication and interaction with the Website.

We use the following types of cookies on the Publisher Platform and Advertiser Dashboard:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. 
  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it (such as Google Analytics).
  • Functionality cookies. These are used to recognize you when you return to our website (such as cookies dropped by Intercom). 

We currently do not directly collect personal data about Listeners through cookies. 

7. Opt-Outs.

Opting out of cookies. If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our service or some of its functionality may be affected. 

Opting out of targeted advertising via Nielsen. We use data we receive from Nielsen to facilitate tailored advertising within your podcast listening experience. If you want Nielsen to stop providing us with your information, please use Nielsen’s opt-out function

Please note that Nielsen’s opt-out function does not opt you out of tailored advertising entirely - it works independently and is unique to each browser on your devices and each IP address that you use to access podcasts. For instance, if you opt out of tailored advertising on your iPad at home but not on your iPhone at home, you may still receive tailored advertising while listening to podcasts on your iPhone. Relatedly, if you opt out on your iPad at home but then listen to podcasts from a different location, you may still receive tailored ads. 

Once you opt out, Nielsen will stop providing us with your data. It can take up to 30 days for our database to update your selection, during which you may still receive tailored advertising.

Promotional Communications. If you are a Publisher or Advertiser who has opted into receiving newsletters from us (which may include updates about new or improved products and features), you may opt out of receiving promotional communications from us by following the instructions in those messages or by contacting us at any time. If you opt out from promotional communications, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

8. Data Security

We are committed to protecting the personal data in our systems. We implement appropriate technical and organizational measures to help protect the security of personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

If you are a Publisher or Advertiser and have an account with us, you are responsible for maintaining the confidentiality of your account password and for any access to or use of your account using your password, whether or not authorized by you.  Please notify us immediately of any unauthorized use of your password or account or any other breach of security.

9. Data Retention and Deletion

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

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

When determining the retention period, we take into account various criteria, such as the type of information, the nature and length of our relationship with you, the impact on such relationship if data is deleted, mandatory retention periods provided by law or statute of limitations.  

10. International Transfers 

Because of the global nature of our business, Spotify shares personal data internationally with Spotify group companies, subcontractors and partners when carrying out the activities described in this Policy. They may process your 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 and the laws which apply where you live

11. Changes to this Policy

We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in case of material changes, we will provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.  

12. Contact Us

Thank you for reading our Policy. If you have any questions about this Policy, please contact our Data Protection Officer by emailing contact-megaphone@spotify.com or by writing to your relevant data controller at the address below.

If you reside within the U.S., the Spotify data controller can be reached at: 

Spotify USA Inc.

150 Greenwich St.

New York, NY 10007

USA

If you reside outside the U.S., the Spotify data controller can be reached at: 

Spotify AB

Regeringsgatan 19

111 53 Stockholm

Sweden

Community Guidelines

We value our community who use the Megaphone Platform, as well as those who enjoy the content made available via the Megaphone Platform. We developed rules for use of the Megaphone Platform to help us foster and protect the community we have worked so hard to build and grow since 2015. 

By using the Megaphone Platform, you agree to abide by the Spotify Platform Rules (“Platform Rules”), in addition to the terms and conditions of your Agreement. Capitalized terms used but not defined herein shall have the meaning set forth in the Agreement.

The Platform Rules contain important information about our expectations of you while using the Megaphone Platform and apply to all content made available through the Megaphone Platform, including but not limited to podcasts, show pages, artwork and episode descriptions. Please take the time to carefully read through the Platform Rules. 

Violation of the Platform Rules may result in removal of any content you’ve made available to the Megaphone Platform or otherwise to Spotify in connection with your use of the Megaphone Platform, and/or termination or suspension of your Megaphone Platform account(s).

Reporting content made available via the Megaphone Platform

Please follow the appropriate process below to notify Spotify of an alleged copyright infringement or other violation relating to content made available via the Megaphone Platform.

Please note, your statements may subject you to legal consequences. You may wish to consult an attorney before submitting a claim.

Copyright Infringement

Spotify respects intellectual property rights and expects its users to do the same. If you are a copyright holder, or its agent, and you believe that any of the copyrighted material made available via the Megaphone Platform infringes your copyrighted work, please let us know.

If the Megaphone Platform content you want to report is available on Spotify, please use this web form to submit a notice of claimed infringement. You may alternatively notify Spotify’s designated copyright agent via the information available in the Spotify Copyright Policy. 

If the Megaphone Platform content you want to report is NOT available on Spotify, you may email us at infringement-claim-megaphone@spotify.com. You may alternatively contact us at the following address:

Spotify C/O Megaphone

150 Greenwich Street 

New York, NY 10007

Please include as much detail as possible to allow us to identify the facts or circumstances, including, where possible:

  1. A physical or electronic signature of the owner (or person authorized to act on behalf of the owner) of the copyright that is allegedly infringed;
  2. Specific identification of each copyrighted work claimed to have been infringed;
  3. A description of where the material believed to be infringing is located on the Megaphone Platform (please be as detailed as possible and provide a URL to help us locate the material you are reporting);
  4. Contact information for the complaining party, such as a complete name, address, telephone number, and email address;
  5. A statement that the complaining party has a good faith belief that use of the work(s) in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
  6. A statement that the information in the notification is accurate, and that the complaining party is the owner of the right that is allegedly infringed, or agent for the owner.

Spotify may pass your name and email address to the allegedly infringing party, and retain your information as long as required for legal purposes. We should also let you know that Spotify has a policy to terminate in appropriate circumstances the accounts of repeat infringers.

Other Violations

Did you find content made available via the Megaphone Platform that you believe otherwise violates the Platform Rules? Please let us know by emailing: support-megaphone@spotify.com.