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Privacy Policy - Transfer to other countries

Privacy Policy - Transfer to other countries

Hi there,

 

The recent changes to the Terms & Conditions and Privacy Policy have prompted me to sit and read through them, and I have a query regarding point 6 of the Privacy Policy (as well as a couple of suggestions around changes like this in general).

 

I'd like to suggest two things:

  1. When changes are made to the Terms and Conditions and/or Privacy Policy, Spotify prepare a short summary of what the changes are. This announcement goes some way, but does not make it clear enough if any of the actual terms changed.
  2. When a change of T&C/PP blocks the service from being used until the new terms have been accepted, you publish the new terms well in advance of the cut-off date, and take action (email/in-app alert) to draw users' attention to it. I've been without Spotify for some time now as I've not had an opportunity to read and accept the new terms.

Many companies have the courtesy to do both of the above when they change their T&Cs, many of which are not charging me a monthly subscription.

 

My query relates to point 6 of your Privacy Policy, which states:

 

6. Transfer to other countries

Spotify processes information about our users on servers located in a number of countries. Spotify may also subcontract processing or share your information to a third parties located in countries, other than your home country. Information collected within the European Economic Area (“EEA”) and Switzerland may, for example, be transferred to, and processed in, a country outside of the EEA and Switzerland.. You expressly consent to this.

 

I would like clarification of what those countries are, and whether the companies based in those countries have signed up to any form of agreement promising to maintain the levels of data protection afforded to us by law within the EEA. Something like the the U.S.-EU Safe Harbor Framework, while subject of much criticism, is still better than nothing and would show some acknowledgement that Spotify (and/or it's partners outside of the EEA) are taking our privacy seriously.

 

Many thanks,

Richard

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