Effective as of September 1, 2015
Pandora operates a personalized Internet radio service and related platform features available through the web at pandora.com, on mobile devices and tablets, in automobiles, and through other consumer electronic devices (the "Pandora Service" or "Service"). As we use it in this policy, "Pandora" refers to Pandora Media, Inc. and its subsidiaries. This policy applies to all Pandora-authorized operations of the Service. We may refer to Pandora as "we", "us", or "our". We may refer to you as "listener", "you", or "your". The purpose of this policy is to inform you about the information we collect, how we use and share that information, and the ways in which you can control how we use and share that information. By submitting your information through our Service, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your information in accordance with this policy.
1. Information We Receive or Collect From You
Registration Data: When you register, we ask you to provide certain information, which includes your email address, birth year, gender, and zip code (the "Registration Data"), as well as a password for your account.
Payment Information: If you choose to subscribe to fee-based portions of the Service, purchase a subscription to the Service as a gift, or purchase add-on products or services, you will also be asked to provide (at a minimum) your name and credit card information ("Payment Information").
Information You Choose to Provide to Pandora: You have the ability to provide a variety of information during your interactions with us and the Pandora Service, such as emails you may send us, polls or surveys you choose to participate in, ads you respond to, and emails or newsletters that you sign up to receive. Pandora or third parties acting on our behalf receive data from you whenever you provide us with any of this type of information.
Listening Activity: When you use the Service, we keep track of your listening activity, which may include the number and title of songs you have listened to, the songs that you like (thumb up) or dislike (thumb down), the stations you create or listen to, the songs you skip, and how long you listen to a station.
Community Posting: You have the ability to post comments and information in community networking features available on or accessible through the Service, such as your public profile, artist and album forums, our blog, and our social networking pages. You should be aware that any information you submit in the course of these community activities can be read, collected, or used by other users of these parts of the Service, as further discussed below. We are not responsible for the information you choose to make public in any of the community networking features available on or through the Service.
Technical Information: As is true of many internet-enabled services, Pandora may collect certain non-personally identifiable technical information through the use of log files and servers. Web and application servers create log files automatically as part of their setup and configuration. Information in a log file may include IP address, browser type, Internet service provider, date/time stamps, MAC address, file requested, and other usage information and statistics.
Contact Information: If you choose to participate in certain features and/or rewards offered through the Service, you may provide us, and we may collect, your contact information, including your name, mailing address, and phone number ("Contact Information"). The email address you provided as part of your Registration Data is not considered Contact Information for the purposes of this policy.
Device Information: If you access and use the Service from a computer, mobile phone, tablet, automobile, or other electronic device, we may collect information about those devices. For example, our servers receive and store information about your computer and browser, including your Internet Protocol (IP) address, browser type, and other related software or hardware information. If you access the Service from a mobile phone, tablet, automobile, or other electronic device, we may collect and store information such as device type, operating system version and type, unique identifiers (such as Android Advertising ID, VIN, MAC address, and IDFA), carrier, and other related information for that device.
Location Information: As part of registration for the Pandora Service, you agree to provide us with, and allow us to use, your zip or postal code. Additionally, we may collect and use approximated or realtime location information, such as GPS location, from devices you use to access the Pandora Service. We will provide you with notice and an opportunity to consent before we access and collect your realtime location information, and depending on your device manufacturer, you may have the ability to revoke this consent at any time.
2. Information We Receive or Collect From Third Parties
We may receive or collect information about you from third parties, and combine and store it on our servers with other information we may have already received or collected from you. These third parties include:
- Service partners that provide or make available advertising, features and functionality, and content on or through the Service.
- Advertising partners that collect and maintain information on their customers. These partners may provide Pandora with certain information about those customers for the purposes of serving advertisements and/or marketing offers to their customers on the Pandora Service.
- Marketing companies and data providers that create, maintain, and distribute professional marketing lists or segments, or maintain and distribute other marketing, or similar data.
- Governmental or quasi- or pseudo-governmental agencies or organizations that provide or make available, to the public, census and demographic data.
- Third-party social media websites, applications, or services that you use, when we allow those websites, applications, or services to interact through the Service to provide personalized services to you. In some cases, those websites, applications, or services may automatically provide us with information about you to facilitate personalization unless you use the controls available on those websites, applications, or services to opt-out of such sharing.
- People who store or post information about you on the community features of the Pandora Service, or by your enabling connectivity with another website, application, or service where friends or other listeners store such information. For instance, your friends may store information about you in places such as their friend lists, address books, or photos on our Service or other websites, applications, or services such as social media applications with which the Pandora Service interacts.
3. Information Collection Technologies
We use both session cookies and persistent cookies. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You may be able to remove persistent cookies by following directions provided in your browser's "help" section. If you do not accept first-party cookies you may still use our Service, but your ability to use some areas of our website, and the ability to stay logged in, will be limited.
Beacons and tracking pixels: Pandora, its third-party advertising partners, and tracking-utility partners employ a technology known as "beacons" or "tracking pixels" (each, a "Beacon"). A Beacon is a one-pixel-by-one-pixel clear image that is embedded in HTML content, and is about the size of a period at the end of a sentence. When HTML content containing a Beacon is rendered, the Beacon transmits anonymous information to a server, such as a numeric count, unique identifier, or IP address. Pandora and its partners use Beacons to help us better manage content on our Service. For example, we may place a Beacon in HTML-based emails to let us know which emails recipients have opened, or on a webpage to count the number of unique visitors to that page. The use of a Beacon may also allow us to gauge the effectiveness of certain communications and of our marketing campaigns.
HTML5 and Flash Local Storage: Pandora and its advertising and technology partners may, in some instances, use HTML5 and/or Flash Local Storage (collectively, "Local Storage") to enhance your listening and advertising experiences on the Service. For example, we use Local Storage to keep track of the current song playing in the event your browser window reloads inadvertently, that way we can continue playing that song starting at the same position it was prior to reload. Our advertising and technology partners may use Local Storage to detect your bandwidth speeds for optimal video playback performance. Each browser implements HTML5 Local Storage differently and provides tools for managing content stored within local storage. Review your browser's privacy settings to manage the content stored within HTML5 Local Storage. Similarly, for more information on how to manage content stored with Flash Local Storage, please review this document provided by Adobe.
4. How We Use Information We Receive or Collect
Generally: In general, Pandora may use your Registration Data and/or other information or data we receive or collect, as well as data we derive or infer from combinations of the foregoing, for a variety of purposes, such as:
- To facilitate the creation of and secure your account on the Pandora Service.
- To customize and personalize the advertising and other content we deliver to you both on the Service and on other services offered by our publishing partners. We use this information to provide you with relevant and interesting advertising and other content.
- To measure and analyze Service usage and enhance the listener experience on our Service. We use tracking information to determine how well each page and station performs overall, based on aggregate listener demographics and traffic patterns to those pages and stations. This helps us continue to build a better Service for you.
- To fulfill your requests for certain products and services, such as distributing electronic newsletters and enabling you to participate in and renew paid services, surveys, and public forums.
- To send you information that you agreed to receive.
- To alert you to the latest developments and features on our Service and to notify you of administrative information, such as security or support and maintenance advisories.
- To invite you to participate in events or special promotions related to artists or products we think you may like or in which you may be interested.
- To pay artists and rightsholders for tracks you hear, by reporting listening information to copyright licensing agencies.
Email Address: We do not sell or give your email address to other companies for their own marketing purposes without your permission. However, we may use your email address or other Registration Data to provide you with technical support, send you notices about the Service or other promotional offers you have elected to receive, and to serve you with ads that are more relevant to your interests. We may also work with data partners and advertising platforms to help increase the relevancy of ads we provide to our listeners. In doing so, we may use information representing an encrypted or hashed value derived from information we have received, such as your email address, in connection with these partners and platforms.
Contact Information: We do not sell or give your Contact Information to companies for their own marketing purposes without your permission. We do use Contact Information, however, to contact you, and to provide you with special offers and other information. For example, if you participate in Pandora's Thumb Rewards program by opting to receive an artist-related reward, or personal call with an artist, we may use your Contact Information to deliver the reward to you, or to contact you and facilitate the call. If you provided your Contact Information as part of your use of Pandora's Artist Marketing Platform, we may use your Contact Information to update you on new features and functionality made available as part of the Artist Marketing Platform, or the status of your music submission. You may at any time request that we cease using your Contact Information by contacting Listener Support.
5. How We Share Information We Receive or Collect With Others
How Your Information Is Shared: Pandora may share information we receive or collect in a variety of ways, such as:
- When you give Pandora permission through an affirmative election (for example, clicking "yes" in response to a message such as "share my email with this advertiser").
- When you participate in community and social networking features on the Pandora Service, such as forums, station sharing, listener opinions and reviews, or other forms of communication and interaction which you elect to make public or share on public profiles or in other public forums.
- If we contract or partner with third parties to provide specialized services on our behalf, such as credit card processors, customer support, ad servers or other providers of advertising services, bulk email processors who send out emails on our behalf, or parties who assist us with sweepstakes management and prize fulfillment. These companies are authorized to use your personal information only as necessary to provide these services to Pandora. They are not authorized to use your personal information for their own, unrelated purposes.
- Sharing information about the artists, tracks, and stations you have created or listened to via the Service, or that are associated with your account, if you have elected to share that information publicly. If your Pandora profile is marked as private, your stations may appear in a search, but your profile will not be linked to that station; however, if someone already knows and enters your entire email address into our search system, they will be able to see a list of all the stations created under that email address.
- If you have given permission to a third party for us to share data about you with them. For example, if you participate as a panelist in a survey with an analytics company, you may, as part of your agreement with that company, have authorized that company to receive data from us about you.
- To measure and analyze Service usage. For example, we use third-party providers such as Nielsen and ScorecardResearch to measure how long and how frequently you are using the Service. Our advertising partners may use these providers to measure the effectiveness of their advertising campaigns. When we use these providers, we provide them with non-personally identifiable information about you, such as your device identifier.
Sharing of Personally Identifiable Information: We do not share personally identifiable information with third parties other than as described in this policy. However, we may share your information, including personally identifiable information, in order to (i) protect or defend the legal rights or property of Pandora, or the legal rights of our business partners, employees, agents, and contractors (including enforcement of our agreements); (ii) protect the safety and security of Pandora users or members of the public including acting in urgent circumstances; (iii) protect against fraud or to conduct risk management; or (iv) comply with the law, legal process, or legal requests. Additionally, we may share your data, including any personally identifiable information, with our successor in interest in the event of a corporate reorganization, merger, or sale of all or substantially all of our assets.
Sharing of Device Data: Pandora may share information from devices you use to access the Service with its third-party vendors or service providers, manufacturing or distribution partners, or advertising partners. We share this information for a variety of purposes such as mobile listening capping, advertising frequency capping, tracking advertising conversion events, estimating the number of unique users, security and fraud detection, debugging problems with the Pandora Service, and for providing you with more relevant advertisements.
Sharing of Anonymized, Non-Personally Identifiable or Aggregated Data: Pandora may share with third parties, advertisers, and/or business partners anonymized, non-personally identifiable, or aggregated data we receive or collect, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Service, or information about the stations, tracks, and artists you listen to, thumb-up, thumb-down, or bookmark. We share such information for a variety of reasons, such as to analyze Service usage, improve the Pandora Service and your listener experience, improve the serving of advertisements, or for other similar purposes. The use and disclosure of such anonymized, non-personally identifiable, or aggregated information is not subject to any restrictions under this policy.
Information You Disclose in a Public Profile or in Public Forums: The Pandora Service offers publicly accessible and available profile pages, community forums (such as artist, song, or advertiser pages), blogs, and pages on social media platforms. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. If your profile is public, any information you place in your user profile, including biographical information, the people you are following, and the people whom you allow to follow you, may be read, collected, and used by others who access them. To request removal of such information from our public forums, contact our Listener Support team. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why. To find out more about how to make your profile private, please see the section below on Pandora Profile Visibility.
Onward Transfer: If your personally identifiable information is transferred as described in this policy, we will seek assurances from the recipients of such personally identifiable information (prior to the transfer) that they will safeguard the personally identifiable information in a manner consistent with this policy. We ask recipients of such information to enter into a contractual relationship with us that includes confidentiality and non-disclosure clauses, and provides the same level of commitment to and protections of information as provided in this Policy.
6. Advertising & Measurement Settings
Opting Out of Behavioral Advertising on the Web: In our effort to provide you with advertisements that may interest you, Pandora and its third-party advertising partners use data in the manner disclosed in this policy to provide you with relevant ads. To learn about how the online advertising industry uses information it collects to provide you with relevant ads, and to control whether you want to receive those relevant ads from third-party advertisers, please review the information at the following links:
Because we do not control the privacy practices of third-party advertising companies, you should read and understand their privacy policies. You acknowledge and agree that you are solely responsible for reviewing the privacy policies of such third-party advertising companies and the methods available, if any, for changing privacy settings and the like.
Opting Out of Behavioral Advertising on Mobile and Tablet Devices: If you are using an iOS device and you do not want to receive tailored in-application advertisements that relate to your interests, you may be able to opt-out by accessing the iAd Network Advertising Settings page in a browser on your iOS-based device. If you are using an iOS 7 or later device, you may also be able to limit the delivery of tailored in-application advertisements by performing the following steps: Open Settings and tap "Privacy", Scroll to the bottom of Privacy and tap "Advertising"; Flip "Limit Ad Tracking" to ON. The above steps and features, although current as of the date of this policy, are not controlled by Pandora and are therefore subject to change at any time. You should contact the platform operator if the above options are no longer available.
If you are using an Android-based device and you do not wish to receive tailored in-application advertisements, you can visit Google's Ads Settings page from a browser on your Android-based device and make your choices there. Pandora does not control how the applicable platform operator allows you to control receiving tailored in-application ads; thus, you should contact the platform operator if the above options are no longer available.
Opting Out of Third Party Service Measurement and Analytics: As disclosed in this policy, we use third-party providers to aid us in measuring and analyzing service usage. You may opt-out of web-based participation in these measurement services by following the instructions on the following web pages for each respective company: Nielsen and Scorecard Research. To opt-out of participation on mobile and tablet devices, please follow the instructions above listed in the section for Opting Out of Behavioral Advertising on Mobile and Tablet Devices.
7. Managing Your Information
Modification of Your Registration Data: We provide you with the ability to modify your Registration Data, which you may do through the Settings section of our Service or by contacting Listener Support. For detailed instructions on how to modify your Registration Data or to otherwise access this information, visit our support site at http://help.pandora.com. We generally respond to email requests within 24 hours of receiving a request, but it may take up to 30 days depending on the volume of requests we receive.
Retention of Your Registration Data and other Information: We will retain and use your Registration Data and the other information we collect about you for as long as your account is active or as needed to provide you Services. We will retain and use this information for the purposes for which it was collected (as specified in this policy or as Pandora discloses to its listeners outside of this policy), including, to provide the Service to you, comply with our legal obligations, resolve disputes, and enforce our agreements.
If you would like to delete your Registration Data, or if you would like more information on cancelling or deactivating your account, see the section below on Cancellation or Deactivation of Accounts.
Your Email Preferences: When you register for the Service, you may elect to receive promotional, marketing, or other similar emails tailored to your interests. You have the option to change this election in the Settings section of our Service. For information on how to opt in or out of receiving promotional, marketing, or other similar emails from us, visit https://help.pandora.com.
Additionally, you may also follow the unsubscribe instructions contained in the promotional, marketing, or other similar emails you receive.
We will send you transaction confirmation emails and other Service-related announcements when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Cancellation or Deactivation of Accounts: If you would like to request the cancellation or deactivation of your account, you should contact our Listener Support team for assistance. Cancellation or deactivation of your account does not ensure complete or comprehensive removal of the content or information you may have posted or otherwise made available publicly on the Service while you were a registered user. You should also contact our Listener Support team to request the deactivation of a profile you believe is fake or otherwise unauthorized.
Pandora Profile Visibility: When you register for the Pandora Service, your profile and listening activity will be public. When the visibility of your Pandora profile is set to public, the Service automatically publishes your listening activity to your profile. For example, if you create a new station or thumb up a song, that activity will be posted in your Pandora profile for members of the public to view. We provide you with the ability to change the degree of visibility of your Pandora profile. For detailed instructions on how to adjust your Pandora profile visibility settings, visit help.pandora.com.
Please note that changes to the visibility of your Pandora profile do not have any impact on the advertising you may see if you use the ad-supported version of the Service.
Cached Profiles on Search Engines: Please note that although we may deactivate your account or make your profile private at your request, Internet search engines such as Google and Bing cache publicly available webpages for a period of time beyond the control of Pandora, and may make your deactivated or formerly public profile available to users of their services on their platforms until such time as they refresh their webpage cache. Please consult with the applicable search engine to determine how you may remove webpages from their webpage cache.
8. Security and Content From Other Websites
Protection of Data From Loss: We have implemented security measures designed to protect against the loss, misuse, and alteration of the information we collect or receive from you. For example, when you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). However, despite our efforts, no security measures are perfect or impenetrable. If you have any questions about security on our Service, you can contact our Listener Support team.
Data Integrity: We will use personally identifiable information, if any, that we collect and receive from you in ways that are relevant and compatible with the purpose for which that information was collected or provided to us as more fully disclosed in this policy. We will take steps to ensure that all personally identifiable information collected, processed, and/or stored is protected from destruction, corruption, or use in a manner inconsistent with the purpose for which we received it.
Links to Other Websites: Our Service and certain advertisements on our Service include links to other websites whose privacy practices may differ from those of Pandora. If you submit personal information to any of those websites, the privacy statements and practices of those websites govern their use of your information. We encourage you to carefully read the privacy statement of any website you visit.
Use of Framing Techniques: Some of our third-party partners may utilize framing techniques to serve content to and from webpages accessible through our Service while preserving the look and feel of our website. Please be aware that if a third-party partner utilizes framing techniques, you are providing your personal information to this third-party partner and not to Pandora.
9. Our Policies Concerning Children
Pandora prohibits registration by, and does not knowingly collect personal information from, anyone under 13 years of age. In the event we obtain actual knowledge that we have collected information from children under the age of 13, we will take measures to remove such information from our servers. If you believe that we might have any personal information from a child under 13, please contact our Listener Support team.
10. Your California Privacy Rights and "Do Not Track"Pursuant to California Civil Code Section 1798.83, this policy sets forth that we only share personal information (as defined in California Civil Code Section 1798.83) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide personal information or when you choose to participate in a feature on the Service. If you do not opt-in or if you opt-out at that time, we will not share your personal information with that identified third party for direct marketing purposes.
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to "Do Not Track" browser settings. Like many other websites and online services, we do not currently alter our practices when we receive Do Not Track signals as there is no consensus among industry participants as to what "Do Not Track" means in this context. To find out more about "Do Not Track," you may wish to visit www.allaboutdnt.com/.
11. European Union-Swiss Safe Harbor
Pandora adheres to the set of data protection principles developed by the United States Department of Commerce, in collaboration with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland, which produced the U.S.-European Union Safe Harbor Framework Documents and U.S.-Swiss Safe Harbor Framework Documents. The privacy principles in this policy are based on these Safe Harbor Principles, including as they relate to personal information transferred from the European Union ("EU") and/or Switzerland to the United States ("U.S.").
Pandora has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the status of Pandora's certification, please visit https://www.export.gov/safeharbor/.
12. Transfer of Information of International Listeners
Please note that the information you submit to us may be transferred to the U.S. and other countries to be processed by us or our service providers in order to provide the Service to you or for such other purposes as set forth in this policy. If you are not a resident of the U.S., you hereby consent and agree that we may collect, process, use, and store your information, as discussed in this policy, outside your resident jurisdiction, including in the U.S. Please be aware that U.S. law and the laws of other countries where we may store and process your information may offer different levels of protection for information than may be available in your country.
We will continue to evaluate this policy against new technologies, business practices, Safe Harbor requirements, and our listeners' needs, and may make changes to the policy accordingly. Please check this page periodically for updates. If we make any material changes to this policy, we will post the updated terms of the policy on the Service, and provide you notice of such chances, which may include notice by email through a message sent to the email address you use to access the Service, or posting a message on the Service.
Any material changes to this policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of notice of the changes on the Service. These changes will be effective immediately for new users of the Service. Please note that at all times you are responsible for updating your information to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your information, you must notify us prior to the effective date of the changes that you wish to deactivate your account. Continued use of the Service following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Enforcement: Pandora will conduct compliance audits of our relevant privacy practices to verify adherence to this policy and will self-certify with the U.S. Department of Commerce for the purposes of EU Safe Harbor compliance. Further, we will conduct follow up investigations to verify that attestations and assertions regarding our privacy practices are accurate. You may inquire about an inaccuracy or make a complaint about a potential violation to us via the contact information provided below. We do engage in training to support implementation and compliance of our privacy practices; any employee that we determine is in violation of this policy may be subject to disciplinary action.
Dispute Resolution: Questions or concerns regarding our use or disclosure of information may be directed to our Listener Support team. Pandora will investigate and attempt to resolve complaints and disputes regarding use and disclosure of information in accordance with the principles contained in this policy. For complaints that cannot be resolved between Pandora and the complainant, Pandora agrees to cooperate with the respective data protection authorities located in the applicable country (or their authorized representatives) and participate in any dispute resolution procedures established by such authorities.
TRUSTe Privacy Seal: Pandora has received TRUSTe's Privacy Seal signifying that this policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification covers only information collected through the website: www.pandora.com and the Pandora mobile application and does not cover the collection of information collected through other downloadable software, automobiles, and other consumer electronic devices. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request.
15. Contact Us