Your California Consumer Privacy Act Rights
Last Updated: July 1, 2024
This California Consumer Privacy Act Disclosures (“Notice”) supplements the information contained in the Pandora Privacy Policy and applies only to California residents regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 (“CCPA”), CCPA as amended by the California Privacy Rights Act of 2020 (“CRPA”) and any implementing regulations adopted thereunder. Terms used herein (including defined capitalized terms) shall have the meanings set forth in the CCPA, CPRA, and the associated regulations, and in our Privacy Policy, Terms of Use, and Artist Marketing Platform Terms of Use.
Your Rights
Under the CCPA, California Consumers have the following rights, all subject to the meanings and exceptions set forth in the CCPA:
- Right to Know or Access – the right to request that we disclose to you what Personal Information we collect, use, disclose, share and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you;
- Right to Delete – the right to request that we delete certain Personal Information we collect about you, subject to exceptions specified under the CCPA;
- Right to Correct – the right to request that we correct inaccurate Personal Information we hold about you;
- Right to Opt-Out of Sale or Sharing – you may opt-out from the sale of your Personal Information, or from the sharing of your Personal Information to a third party for cross-context behavioral advertising and
- Right to Limit the Use and Disclosure of Sensitive Personal Information – you may tell us to limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including for use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
More information on each of these rights is below. In your request, you must provide enough information to allow us to verify that you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity. Please note to ensure the integrity of our systems and the proper fulfillment of your request, we cannot simultaneously process requests for access and deletion. Please wait until you are notified that a pending request for access or deletion has been completed before submitting a subsequent request for the second process.
Right to Limit the Use and Disclosure of Sensitive Personal Information
As disclosed in the chart below, some of the personal information we collect may be considered Sensitive Personal Information under California law. This includes race or ethnicity, religion, and precise geolocation derived from a device and intended to locate a consumer. If you are a California Consumer and would like to exercise your Right to Limit Use and Sharing of such Sensitive Personal Information, please submit your request here or send an email request to privacy@pandora.com.
Do Not Sell My Personal Information or Share For Cross Contextual Behavioral Advertising
We sometimes share personal information to third parties as disclosed in the chart below, which in some instances may qualify as a sale under CCPA. If you use us or tell us directly to share your Personal Information with a third party, that disclosure is not a sale.
We share Personal Information to third parties for the purpose of cross-context behavioral advertising, i.e. targeted advertising.
If you are a California Consumer and would like to exercise your Right to Opt-out of Sale or Sharing for Cross-Contextual Behavioral Advertising, please submit your request here.
Cookie-Based Opt-Outs for Do Not Sell My Personal Information or Share for Cross-Contextual Behavioral Advertising
Pandora engages third parties in online advertising practices, which may be considered a sale or sharing for cross-context behavioral advertising, as defined in the CCPA and CPRA. You may opt out of cookies set by third parties by launching the Cookie Settings from the footer of our web pages. In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of personal information by some or all of the participating companies. For more information, visit https://www.privacyrights.info/.
Right to Know
As a California Consumer, you have the right to know the categories of personal information we have collected about you, the categories of sources from which personal information is collected, our business and commercial purposes for collecting or selling personal information, and the categories of personal information we have disclosed for a business purpose, the categories of third parties with whom we share personal information, the categories of personal information we have sold and the categories of third parties to whom the personal information was sold, in the 12-month period preceding our receipt of your request. You also have the right to request access to the specific pieces of personal information we have collected about you in the preceding 12-month period, or upon specific request, since January 1, 2022, which we will deliver to you electronically, in a portable format where feasible. If you are a California Consumer and would like to exercise your Right to Know, please submit your request here. You can submit up to two requests to know within a 12-month period. In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
Right to Delete
California Consumers have the right to request deletion of the personal information about you that we have collected from you, subject to the exceptions set forth under the CCPA. If you are a California Consumer and would like to exercise your Right to Delete, please submit your request at here.
Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.
If you are the master account holder of a Family Plan, deletion of your data may affect playlists and other content shared with the other accounts linked to your plan.
Please note that if you have an active Pandora account when you request deletion, we will not close your account. We will retain such information as is necessary to allow you continued access to the Pandora Service, maintain your contact preferences, and to service and manage your account. If you wish to close your account, please see this Help Center article.
Please note that even in light of a request for deletion, we are unable to delete information needed to:
- Continue to provide service(s) if you have an active subscription to the Service, provide goods or services you’ve requested, complete a transaction or perform a contract;
- Help ensure security and integrity;
- Identify, repair, and debug errors that impair the Service, our systems, or other functionality;
- Comply with legal or reporting obligations, including to pursue or defend legal claims, exercise or enable others to exercise any rights provided by law, enforce or comply with contractual obligations, respond to valid requests for information, and comply with or enforce applicable laws and regulations;
- Enable other internal uses consistent with your expectations based on your relationship with us or the context in which you provided the information; or
- Enable or enforce any other exceptions provided by CCPA or CPRA.
Right to Correct Inaccurate Information
California Consumers have the right to request that we correct inaccurate information we hold about you. If you are a California Consumer and would like to exercise your Right to Correct, you may do so directly online through your account or by contacting Pandora Listener Care at support@pandora.com.
Right to Nondiscrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising any of your CCPA and CPRA rights.
Verification
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. For your protection, you must provide sufficient information to verify your identity in order for us to fulfill a request to access, delete or correct personal information. Because Pandora collects limited information at registration, you must provide, and have access to, the email account associated with your Pandora account in order to complete the verification step. If you cannot receive email at the email address associated with your Pandora account, you will need to update the email address before submitting a request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
Authorized Agents
If you are an authorized representative submitting a request on a California Consumer’s behalf, please submit the applicable request pursuant to these instructions along with a written permission signed by the individual who is the subject of the request, authorizing you to make the request on their behalf. The written permission must state your full legal name and the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your submission the nature of your request. Both your identity and that of the consumer may be independently verified before we fulfill your request. We may ask the consumer to verify their identity directly with us, unless as an authorized agent, you are acting specifically pursuant to a power of attorney under the California Probate Code. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request. For the safety and security of our customers, any specific pieces of Personal Information requested under a CCPA Right to Access request will be returned to the requesting customer and not to an authorized agent, unless the authorized agent is acting specifically pursuant to a power of attorney under the California Probate Code.
Users Younger Than 16
Pandora does not knowingly collect Personal Information of any users under 13 years of age and will not sell or share Personal Information of users between 13 and 16 years of age without obtaining affirmative consent.
Collection and Sharing of Personal Information
Categories of Personal Information We Collect
The information we collect is described further in our Privacy Policy, which you should review in addition to the lists set forth below. In addition to the below, we may collect and/or use additional types of information and will do so only after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.
Below are the categories of Personal Information collected by Pandora after January 1, 2022.
Identifiers and contact information, including email address, zip code, account name or alias, password, device and other technological identifiers, unique personal identifiers, and IP address. We may collect the following additional information if you use these products or features:
- Pandora Community: You may choose to provide your name, location (city, state, or country), instant messaging (IM) screen names, and a personal webpage.
- Pandora profile: You may choose to provide your hometown.
- Purchases: If you purchase a product or service from Pandora, we collect your name and billing zip code for the purposes of processing your payment.
- Family plan: If you are the main account holder of a Family subscription, we collect the email addresses of any family members you add to your account.
- Pandora Artist Marketing Platform (AMP): You may provide your name or the name of the artist whom you represent. If you apply to be a Pandora Stories curator, we collect your country. If you apply to Pandora for Podcasters, you may provide your name, social feeds, and the podcast owner’s email address and telephone number.
- Pandora for Brands: If you request a media kit, we collect your name, company email, company phone, and zip.
- Student and military discounts: If you apply to receive these discounts, we may collect your name in order to verify your eligibility for the discount.
- Other: Except as stated above, we do not collect postal addresses or telephone numbers in the regular course of business, but we may collect this information if you’ve provided it to us in postal mail or email correspondence, to assist in resolving a customer support request, or in connection with a special offer or event.
- Payment information, if you purchase a product or service directly from Pandora. If you pay with a credit card, this includes the first and last four digits of your payment card and card expiration date. If you pay with PayPal, we receive identifiers associated with your billing agreement and transactions.
- Collected characteristics, such as gender, birth year, music and content preferences, account status, and consumer interest segments.
- Commercial information, including products or services purchased, obtained, or considered from Pandora or others, or other purchasing or consuming histories or tendencies.
- Internet or other activity information, including listening history, bookmarked or thumbed content on our Service, browsing history, search history, interactions with our Services (including our websites and mobile applications), and interactions with advertisements.
- Geolocation data, defined as “device-based location information” in our Privacy Policy. If you have permitted the Pandora app to access location services on your device, device-based location information may be derived from GPS and nearby wireless signals such as cell towers, Wi-Fi networks, and Bluetooth beacons.
- Audio and visual information, including voice utterances as described in our Privacy Policy, pictures you upload to your Pandora profile or Pandora Community, and Your Content, as described in our Terms of Use.
- If you are an AMP user, we collect Your Content, as described in the Artist Marketing Platform Terms of Use, including voice recordings you may provide, and a photo if you choose to provide one.
- Professional or employment-related information, including your employer (if you choose to provide it on your Pandora Profile), and any professional or employment information you choose to provide in connection with your registration for or submissions to the AMP Service, Pandora for Podcasters, Pandora Stories, and Pandora for Brands. If you apply to receive our military discount, we may collect your military affiliation (e.g. active duty, veteran) in order to verify your eligibility for the discount.
- Education information, such as your current school (if you choose to provide it on your Pandora Profile). If you apply to receive our student discount, we may collect the name of your university in order to verify your eligibility for the discount.
- Inferences drawn from any of the information we collect. We may infer your ethnicity, income, whether you are a parent, political affiliation, whether you are a traveler, and consumer interest segments. We may infer your approximate location using the IP address currently assigned to your device.
- Sensitive Personal Information (“SPI”), such as an account log-in, debit or credit card number in combination with password or other credentials, or information that reveals racial or ethnic origin, religion, health diagnoses or treatment, sexual orientation, or precise geolocation within 1750 feet. We may collect or infer SPI from sources described below.
- Other personal information, including any biographical or other personal information you choose to provide in profile, biography, or free-form fields if you use any of the following products or features: Pandora profile, Pandora Community, AMP profile, and Pandora Stories curator bio. If you opt to participate in consumer research panels or surveys, we may collect any personal information you elect to provide as a part of that research.
Uses of Categories of Personal Information (PI)
Category of PI collected | Categories of Sources of PI | Business or Commercial Purposes for which PI is Collected | Categories of Third Parties to whom this type of PI May Be Disclosed for a Business Purpose | Categories of Third Parties to whom this type of PI May Be Sold or Shared for Cross Contextual Behavioral Advertising |
Identifiers and Contact Information |
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Payment information |
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None |
Collected Characteristics |
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Commercial information |
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Internet or other activity information |
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Geolocation Information |
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Audio and visual information |
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None |
Inferences drawn from information we collect |
We may draw inferences ourselves or acquire them from third parties such as advertising networks and data providers |
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Sensitive Personal Information |
We may collect SPI from:
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We may use SPI to:
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We may disclose SPI for business purposes to:
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CCPA Consumer Privacy Request Metrics
Metrics for Pandora’s receipt and handling of verified California consumer privacy requests for 2023 are set forth in the table below:
Brand | Request Type | #Received | #Completed | #Denied/Closed | Average Days to Resolve | |
Pandora |
Do Not Sell/Share My Information |
715 |
715 |
0 |
3 |
|
Pandora |
Delete My Information |
21 |
21 |
0 |
8 |
|
Pandora |
Access My Information |
58 |
57 |
1 |
28 |
|
Pandora |
Limit Use of My Sensitive Information |
41 |
40 |
1 |
11 |
A request may be denied or closed for the following reasons –
- The request was incomplete, and the submitter did not respond to complete the request.
- The identity of the requestor could not be verified based on the information provided.
- An agent placing a request failed to provide sufficient documentation to verify their authorization.
- A duplicate request was submitted.