Your US State Privacy Rights (Notice at Collection)

ARCHIVED 2023-07-01, DATE APPROXIMATE · VERSION 20230701_rev01 · COMPARED WITH 20230501_rev01

Full text changes — 20230501_rev01 to 20230701_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+Effective January 1, 2023
+This notice to California residents is provided under California law. It provides our "Notice at Collection," provides certain mandated disclosures about our treatment of California residents' information, both online and offline, explains your privacy rights, and provides our "Notice of Financial Incentives."
+This notice to California residents is provided under California law. It explains your privacy rights, provides our "notice at collection," and provides certain mandated disclosures about our treatment of California residents' information, both online and offline.
+### NOTICE AT COLLECTION
+### NOTICE OF COLLECTION OF PERSONAL INFORMATION
+We may collect the following categories of personal information (as defined in the California Consumer Privacy Act (CCPA) and the California Customer Records statute), including sensitive personal information (as defined in the CCPA):
+We may collect the following categories of personal information about our guests and users of our digital properties: identifiers/contact information, demographic information (such as gender and age), payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
+- **Identifiers**, such as name, email address, username and password, postal address, telephone number, signature, government-issued identifier, license plate number, IP address, and other similar identifiers.
+- **Characteristics of protected classifications and demographic information**, such as gender, age, race, disability status, sexual orientation, gender identity, military/veteran status, marital status, national origin, and medical information.
+- **Commercial information**, including information about your interests and consuming history or tendencies, such as products or services considered; transaction information when you request information, contact Guest Services, or purchase, return, request or exchange a product or service, including payment card information or other financial information; information provided in response to surveys or other research conducted on our behalf; and information you provide in public forums.
+- **Internet or other electronic network activity information**, including information regarding your interactions with us online and information we obtain from third parties about use of our applications on third-party platforms or devices.
+- **Geolocation data**, including precise or approximate location information provided by a mobile device or other device or product interacting with or detected by our sites, applications, or physical properties, where we are permitted by law to process this information.
+- **Audio, electronic, visual, or similar information**, including telephone call recordings, other voice recordings, and still or video images captured by cameras or readers on or around our physical properties.
+- **Inferences based on the above.**
+We collect this information so that we can best serve you, including to fulfill your requests and to share offers that we think you may be interested in. A more detailed description of these purposes is in our Privacy Policy under "[Use of Your Information by The Walt Disney Family of Companies](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)."
+We collect this information so that we can best serve you, including to fulfill your requests and to share offers or information that we think you may be interested in. As further described in the "[Use of Your Information by The Walt Disney Family of Companies](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)" section in our Privacy Policy, we generally collect and use the above-listed categories of personal information to provide and manage our sites, applications, products, and services, and for other business or commercial purposes, such as advertising, marketing, and to improve our products and services.
+Disclosures/Sharing/Selling
+Certain data collection on our sites and applications by third parties for purposes of interest-based advertising and social media tools may be a "sale" or "sharing" under California privacy law. As defined by California law, we "sold" or "shared" certain data elements within the following categories of personal information: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above.
+California residents also have the right to "[opt out](https://privacy.thewaltdisneycompany.com/en/dnssmpi)" of the "sale" or "sharing" of their "personal information" to or with "third parties" (as those terms are defined under law).
+If you would like to opt out of the sale or sharing of your personal information, you may click the "Do Not Sell or Share My Personal Information" link in our website footers or in our application settings. Please note that your opt-out choice is specific to the digital property and to the device and browser you are using. You may additionally choose to provide the information requested in this [opt-out form](https://privacyportal-de.onetrust.com/webform/64f077b5-2f93-429f-a005-c0206ec0738e/de88148a-87d6-4426-95b1-ed444dd53281), which may enable us to take action on your opt-out request more broadly than for a specific digital property.
+### "DO NOT SELL OR SHARE MY PERSONAL INFORMATION" RIGHTS
+We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our [Privacy Policy](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/), including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.
+You or your authorized agent can opt out of the "sale" or "sharing" of your personal information to third parties.
+More information, including a description of your legal rights, can be found in the "California Privacy Rights" section below.
+Certain data collection on our sites and applications for purposes of interest-based advertising and social media tools may be a "sale" or "sharing" under California privacy law. Instructions for how you can exercise these rights are set forth below in the "California Residents' Rights" section.
+### ADDITIONAL PRIVACY MANDATORY DISCLOSURES
+### CALIFORNIA RESIDENTS' RIGHTS
+We also make the following disclosures for purposes of compliance with California privacy law:
+Right to Access
+- We collected the following categories of personal information in the last 12 months: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
+- The sources of personal information from whom we collected are: directly from our guests, third-party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.
+- The business or commercial purposes of collecting personal information are as summarized in our "Notice at Collection" section, and as described in more detail in our Privacy Policy under "[Use of Your Information by The Walt Disney Family of Companies](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)."
+- We disclosed certain data elements within the following categories of personal information for a business purpose in the last 12 months: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to business partners, service providers, government entities, and other third parties as described in the "[Sharing Your Personal Information with Other Entities](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)" section of the Privacy Policy.
+- As defined by applicable law, we "sold" or "shared" certain data elements within the following categories of personal information in the last 12 months: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above. We "sold" or "shared" each category to or with entities who provide advertising, marketing, or audience measurement; other online third-party branded tools or functionality (such as maps or video players); and social networks.
+- The business or commercial purposes of "selling" or "sharing" personal information is to assist us with advertising, marketing, audience measurement, and other functionality on our digital properties.
+- We do not "sell" or "share" the personal information of known minors under 16 years of age.
+- We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations.
+### YOUR CALIFORNIA PRIVACY RIGHTS
+_Right to Know_
+You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.
+_Right to Access_
 You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
+Right to Delete
+_Right to Delete_
 You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
+Right to Correct
+_Right to Correct_
 You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
+Right to Opt Out of Sale or Sharing of Personal Information
+_Right to Opt Out of Sale or Sharing of Personal Information_
 You have the right to "opt out" of the "sale" or "sharing" of your "personal information" to or with "third parties" (as those terms are defined by applicable law).
+### Exercising your California Privacy Rights
+_Removal of Content_
+If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.
+Making Access, Deletion, and Correction Requests
+_Shine the Light_
+California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of The Walt Disney Family of Companies to third parties for the third parties' direct marketing purposes. The Walt Disney Family of Companies does not share guests' personal information with other member companies or others outside The Walt Disney Family of Companies for those parties' direct marketing use unless a guest elects that we do so.
+To make an access, deletion, or correction request, please visit [usprivacy.disney.com](https://usprivacy.disney.com/). Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
+_Right Not to Receive Discriminatory Treatment_
+You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information. For example, if you exercise your right to opt out of "sale" or "sharing" of your "personal information," the ads you view may not be tailored to your interests.
+Instructions for Authorized Agents Making Requests
+### EXERCISING YOUR CALIFORNIA PRIVACY RIGHTS
+You may also use an authorized agent to submit an access, deletion, or correction request on your behalf. Authorized agents may submit such requests at [usprivacy.disney.com/agents](https://usprivacy.disney.com/agents/). An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Before completing requests from authorized agents, we may contact you directly to confirm you've given your permission and/or to verify your identity.
+_Making Requests to Know, Access, Delete, or Correct Your Personal Information_
+To make a request to know or to make an access, deletion, or correction request, please visit [usprivacy.disney.com](https://usprivacy.disney.com/). To submit a request by phone, you may call (877) 466-6669. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
+Making Requests to "Opt Out" of the "Sale" or "Sharing" of "Personal Information"
+_Making Requests to Opt Out of the Sale or Sharing of Personal Information_
+To submit a request to "opt out" of the "sale" or "sharing" of your "personal information," you may click the "Do Not Sell or Share My Personal Information" link in our website footers or in our application settings, or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control ("GPC"). We will process the GPC signal as a request to opt out.
+To submit a request to opt out of the sale or sharing of your personal information, you may click on the link "Do Not Sell or Share My Personal Information" on the footer of our websites or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control ("GPC"). We will process the GPC signal as a request to opt out. You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so. Authorized agents may submit requests to opt out by visiting [usprivacy.disney.com/agents.](https://usprivacy.disney.com/agents/) You have the right not to receive discriminatory treatment for the exercise of your privacy rights.
+_Instructions for Using an Authorized Agent to Make Requests_
+You may use an authorized agent to submit a request to know or an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you've given your permission and/or to verify your identity. Authorized agents may submit requests at [usprivacy.disney.com/agents](https://usprivacy.disney.com/agents).
+### CALIFORNIA MANDATORY DISCLOSURES
+_Making Requests for Removal of Content_
+California residents under the age of 18 may make requests to remove content by sending an email with a detailed description of the specific content or information to be removed to [usprivacy@twdc.com](mailto:usprivacy@twdc.com). Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
+We also make the following disclosures for purposes of compliance with California privacy law:
+_Making Shine the Light Request_
+To make a request for information under the Shine the Light Act, please send an email to [usprivacy@twdc.com](mailto:usprivacy@twdc.com).
+- We collected the following categories of personal information in the last 12 months: identifiers/contact information, demographic information (such as gender and age), payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
+- The sources of personal information from whom we collected are: directly from our guests, third-party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.
+- The business or commercial purposes of collecting personal information are as summarized above and in our Privacy Policy under "[Use of Your Information by The Walt Disney Family of Companies.](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)"
+- We disclosed the following categories of personal information for a business purpose in the last 12 months: identifiers/contact information, demographic information (such as gender and age), payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the "[Sharing Your Information with Other Entities](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)" section of our Privacy Policy.
+- As defined by applicable law, we "sold" or "shared" the following categories of personal information in the last 12 months: identifiers/contact information, Internet or other electronic network activity information, and inferences drawn from the above. We "sold" or "shared" each category to or with advertising networks, data analytics providers, and social networks.
+- The business or commercial purpose of "selling" or "sharing" personal information is to assist us with marketing, advertising, and audience measurement.
+- We do not "sell" or "share" the personal information of known minors under 16 years of age.
+### CALIFORNIA PRIVACY RIGHTS METRICS
+Shine the Light Act
+_Request to Know_
+If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of The Walt Disney Family of Companies to third parties for the third parties' direct marketing purposes. We take great pride in the relationship of trust we have built with our guests over many years and we are dedicated to treating your personal information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), members of The Walt Disney Family of Companies do not share guests' personal information with other member companies or others outside The Walt Disney Family of Companies for those parties' direct marketing use unless a guest elects that we do so.
+Requests Received: 474
+Requests Completed in Whole or in Part: 377
+Requests Denied\*: 97
+Average Days to Complete: 7
+Removal of Content
+_Request to Delete_
+If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.
+Requests Received: 2,919
+Requests Completed in Whole or in Part: 2,589
+Requests Denied\*: 330
+Average Days to Complete: 6
+To make such a request, please send an email with a detailed description of the specific content or information to [usprivacy@twdc.com](mailto:usprivacy@twdc.com). Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
+_Do Not Sell My Personal Information_
+### CALIFORNIA PRIVACY RIGHTS METRICS
+Requests Received: 62,930
+Requests Completed in Whole or in Part: 62,930
+Requests Denied\*: 0
+Average Days to Complete: 1
+Request to Know
+This data reflects all requests received from individuals in the US as well as certain requests from individuals outside of the US between January 1 and December 31, 2022.
+Requests Received: 296
+Requests Completed in Whole or in Part: 242
+Requests Not Completed\*: 54
+Average Days to Complete: 7
+\* Requests may be denied in whole or in part due to various factors including because a request was not verifiable, was not made by a consumer, was made multiple times, or called for information exempt from disclosure.
+Request to Delete
+### NOTICE OF FINANCIAL INCENTIVES
+Requests Received: 1,786
+Requests Completed in Whole or in Part: 1,569
+Requests Not Completed\*: 217
+Average Days to Complete: 6
+Members of The Walt Disney Family of Companies may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the "Programs."
+Do Not Sell My Personal Information
+To learn more about the details of our Programs, including the material terms, please visit our [Loyalty Programs/Financial Incentives page](https://privacy.thewaltdisneycompany.com/en/loyalty-programs-and-financial-incentives/), where you can review the specific terms of each Program and learn how to opt out at any time in accordance with the applicable terms of each program. If you have any questions or require assistance, please contact us at [usprivacy@twdc.com](mailto:usprivacy@twdc.com).
+Requests Received: 31,777
+Requests Completed in Whole or in Part: 31,777
+Requests Not Completed\*: 0
+Average Days to Complete: 1
+In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see "[Types of Information We Collect](https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/)" in our Privacy Policy. Because we collect personal information, the Programs may be considered to be "financial incentives" or "price or service differences" under California law.
+This data reflects all requests received from individuals in the U.S. as well as certain requests from individuals outside of the U.S. between January 1 and December 31, 2021.
+To the extent the Programs are reasonably related to the value of guest personal information, the method for calculating this value would include the expenses related to our offer (such as the costs of providing discounts, free shipping, or other promotions, intellectual property or marketing costs, and other related expenses). The value of the guest personal information that we collect will vary depending on the engagement by each guest.
+\* Requests may not be completed due to various factors including because a request was not verifiable, was made multiple times, or where we did not have any personal information associated with the requester.
 ### CONTACT INFORMATION
+If you have a question about our privacy policies, please send an email to [usprivacy@twdc.com](mailto:usprivacy@twdc.com) or write us at:
+CA Privacy Rights
+Disney Interactive Media Group
+South Buena Vista Street
+Mail Code 7667
+Burbank, CA 91521-7667
+If you have a question about our privacy policies and information practices, please send an email to [usprivacy@twdc.com](mailto:usprivacy@twdc.com).