Disney Children's Privacy Policy

FIRST SEEN 2026-07-29 · VERSION 20260729_rev01 · COMPARED WITH 20170501_rev01

Full text changes — 20170501_rev01 to 20260729_rev01

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+**Updated: 04/7/2017**
+TWDC offers a range of websites and apps that are directed to children, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Those websites and apps provide a variety of offerings, some of which may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In the event we discover we have collected information from a child in a manner inconsistent with COPPA's requirements, we will either delete the information or immediately seek the parent's consent for that collection.
+The Walt Disney Family of Companies ("TWDC"), including for example Club Penguin and MarvelKids, is committed to protecting the privacy of children who use our sites and applications. This Children's Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 ("child" or "children"), and uses terms that are defined in our general [Privacy Policy](https://disneyprivacycenter.com/privacy-policy/). This policy is in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA"), and outlines our practices in the United States and Latin America regarding children's personal information. For more information about COPPA and general tips about protecting children's online privacy, please visit [OnGuard Online](http://www.onguardonline.gov/articles/0031-protecting-your-childs-privacy-online).
+#### **Registration**
+TWDC has received TRUSTe's Privacy Seal signifying that this Children's Online Privacy 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 only applies to the digital properties listed on the validation page. If you have questions or concerns regarding our Children's Online Privacy Policy or practices, please contact us at the contact information located in Section 3 below. 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](https://feedback-form.truste.com/watchdog/request).
+Some of our websites and apps allow children to register to view content, play digital games, save gameplay progress, log achievements, participate in contests, and engage in interactive experiences, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent's contact information, such as an email address, and the child's first name, gender, member or account username, and password. We may also ask for a date of birth from children to validate their ages. We strongly advise children to never include any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
+#### 1\. The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents
+**About the Collection of a Parent's Contact Information:** Consistent with the requirements of COPPA, on any child-targeted website or app, or in any instance where we ask for age and determine that the registered user is under the age of 13, we will ask for a parent's email address, or other contact information, before we collect any personal information from the child. If you believe your child is participating in an online activity that collects personal information and you or another parent has not received an email or message providing notice or seeking your consent, please feel free to contact us at [privacycontact@twdc.com](mailto:privacycontact@twdc.com). We will not use contact information obtained for parental consent purposes to advertise to the parent.
+TWDC offers to its users a range of sites and applications, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our sites and applications offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA's requirements, we will either delete the information or immediately seek the parent's consent for that collection.
+#### **Content Generated by a Child**
+****Registration****
+Certain activities on our websites and apps allow children to create or manipulate content and save it with TWDC. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories, open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, TWDC also plans to post the content publicly or share it for a third party's own use, we will obtain a higher level of parental consent, as described below.
+Children can, in many cases, register with our sites and applications to view content, play games, participate in contests, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian's email address, the child's first name and gender, the child's member or account username, and password. We also may ask for birth dates from children to validate their ages. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
+**About Verifiable Parental Consent:**
+**About the collection of parent email address:** Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at [privacycontact@disney.com](mailto:privacycontact@disney.com). We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
+**Email Consent.** In the event TWDC wishes to collect online personal information from a child, COPPA requires that we first seek a parent's consent by email. In the email, we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent's contact information and any other information collected from the child in connection with that activity.
+****Content Generated by a Child****
+**High-Level Consent.** In the event TWDC collects online personal information from a child that will be posted publicly or shared for a third party's own use, we will seek a higher level of consent than email consent. Such "high-level" methods of consent include, but are not limited to, asking for a credit card or other payment method for verification (which may include a nominal charge), speaking to a trained customer service representative by telephone or video conference, or requiring a signed parental consent form by mail, email attachment, or physical submission. After providing high-level consent, a parent may have the opportunity to use a PIN or password in future communications as a way to confirm the parent's identity.
+Certain activities on our sites and applications allow children to create or manipulate content and save it with TWDC. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, TWDC also plans to post the content publicly or share it with a third party for the third party's own use, we will obtain a higher level of parental consent.
+#### **Contests and Sweepstakes**
+**About Verifiable Parental Consent:**
+For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as a first name (to distinguish among family members) and parent contact information, such as an email address (to notify the parent where required by law). We only contact parents to request additional personal information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
+**Email Consent.** In the event TWDC wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian's consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
+Of course, some contests and sweepstakes ask the child to submit their own created content along with the child's entry. In those instances, we may require parental consent prior to submission. Please see [Content Generated by a Child](https://privacy.thewaltdisneycompany.com/en/for-parents/childrens-online-privacy-policy/) section above for more information on our collection, notice, and consent policies.
+**High-Level Consent.** In the event TWDC collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such "high-level" methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent's identity.
+#### **Email Contact with a Child**
+**Teacher consent in lieu of a parent.** With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child's educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the [FERPA site](http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html).
+On occasion, in order to respond to a question or request from a child, TWDC may need to ask for the child's online contact information, such as an email address. TWDC will delete this information promptly after responding to the question or request.
+****Chat****
+In connection with certain activities or services, we may collect a child's online contact information, such as an email address, in order to communicate with the child more than once. In such instances, we will retain the child's online contact information to honor the request and for no other purpose, such as advertising. One example could be a newsletter that provides occasional updates about a website, game, activity, movie, television show, or character. Whenever we collect a child's online contact information for ongoing communications, we will simultaneously require a parent's email address in order to notify the parent about the collection and use of the child's information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions, a child may be engaged in more than one type of ongoing communication, and a parent may need to "opt out" of each communication individually.
+Certain games and activities that are directed to children allow users to communicate directly with other users by means of a chat system. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
+#### **Push Notifications**
+Where TWDC employs a chat system that does not filter all or nearly all personal information, we will first seek high-level consent from the parent.
+Push notifications are app-related notifications on mobile devices that can communicate with the device holder even when the app is not in use. We will require a child to provide a parent's email address before the child can receive push notifications from any of our child-directed apps that collect a device identifier. We will then seek parental consent via email. We will not associate the device identifier with other personal information without contacting the parent to get consent.
+****Contests and Sweepstakes****
+#### **Geolocation Data**
+For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
+If a child-directed TWDC website or app collects geolocation information from a child that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
+Of course, some contests and sweepstakes ask the child to submit their own created content along with the child's entry. In those instances, we may require parental consent prior to submission. Please see [Content Generated by a Child](https://disneyprivacycenter.com/kids-privacy-policy/english/) above for more information on our collection, notice, and consent policies.
+#### **Audio Files**
+****Email Contact with a Child****
+We may offer opportunities to use interactive voice features in some child-directed contexts. In such cases, we implement appropriate technical measures to ensure that we do not collect or retain personal information, including voice recordings, from children as users of our online products or services.
+On occasion, in order to respond to a question or request from a child, TWDC may need to ask for the child's online contact information, such as an email address. TWDC will delete this information immediately after responding to the question or request.
+#### **Persistent Identifiers**
+In connection with certain activities or services, we may collect a child's online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child's online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a site, game/activity, television show, personality/character, or feature movie. Whenever we collect a child's online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child's information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to "opt-out" of each communication individually.
+When children interact with us online, certain information may automatically be collected to make our websites and apps more interesting and useful, and for various purposes related to our business and operations. Examples include the type of operating system, the child's IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our websites or apps, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, pixels, tags, software development kits (SDKs), application program interfaces (APIs), web beacons, and other unique identifiers (which we describe further in our [Online Tracking Technologies and Advertising](https://privacy.thewaltdisneycompany.com/en/privacy-controls/online-tracking-and-advertising/) page). This information may be collected by TWDC or by our service providers. This data is principally used for internal operation purposes, in order to:
+****Push Notifications****
+- provide children with access to features and activities on our websites and apps;
+- customize content and improve our websites and apps;
+- conduct research and analysis to address the performance of our websites and apps;
+- generate anonymous reporting for use by TWDC;
+- show contextual advertising and ensure users do not see the same ads over and over again;
+- help users stay safe while using our services and help our services stay protected; and
+- help ensure compliance with the rules and laws in the places where we operate.
+Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed applications that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
+On applicable child-directed websites and apps, or where we knowingly collect persistent identifiers from children, we take steps to ensure that the use of persistent identifiers is necessary to:
+****Geolocation Data****
+- maintain or analyze the functioning of the website or app;
+- perform network communications;
+- authenticate users of, or personalize the content on, the website or online service;
+- serve contextual advertising on the website or online service or cap the frequency of advertising;
+- protect the security or integrity of the user, website, or online service; and/or
+- ensure legal or regulatory compliance.
+If a child-directed TWDC site or application collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
+We have also implemented appropriate administrative, technical, and organizational measures on these websites or apps to ensure that persistent identifiers are not used or disclosed to contact a specific individual, including through behavioral advertising, to amass a profile on a specific individual, or for any other purpose except internal operations specified in this Children's Online Privacy Policy. These measures include:
+****Persistent Identifiers****
+- restricting the use of behavioral advertising to children on our child-directed websites and apps;
+- restricting the use of features or services that involve building profiles based on the persistent identifiers of children on our child-directed websites and apps;
+- contractually obligating our service providers to adhere to relevant restrictions in this Children's Online Privacy Policy; and
+- verifying that our child-directed websites and apps adhere to the requirements set forth in this Children's Online Privacy Policy.
+When children interact with us, certain information may automatically be collected, both to make our sites and applications more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child's IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers (which we define under the "[Online Tracking Technologies](https://disneyprivacycenter.com/twdc-privacy-controls/online-tracking-and-advertising/)" section of our general [Privacy Policy](https://disneyprivacycenter.com/privacy-policy/)). This information may be collected by TWDC or by a third party. This data is principally used for internal purposes only, in order to:
+In the event we collect (or allow others to collect) other types of personal information from children on our websites and apps for other purposes, we will notify parents, obtain consent prior to such collection, and provide a supplement to this privacy notice, as applicable.
+- provide children with access to features and activities on our sites and applications
+- customize content and improve our sites and applications
+- conduct research and analysis to address the performance of our sites and applications
+- generate anonymous reporting for use by TWDC
+Visit the [Internal Operations Service Providers](https://privacy.thewaltdisneycompany.com/en/internal-operations-service-providers/) page to see the list of our service providers who, as operators, may collect persistent identifiers on our websites and apps subject to contractual processing limitations.
+In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.
+The list of third-party operators who collect persistent identifiers on our sites and applications may be found [here](https://disneyprivacycenter.com/third-party-operators/).
 Please contact us at the mailing address, email, or phone number below with questions about the operators' privacy policies and collection and use practices:
+Disney Interactive
+Disney DTC LLC
 South Buena Vista Street
+Mail Code 7667
+Burbank, CA 91521-7667
+Mail Code 7830
+Burbank, CA 91521-7830
 United States of America
 Phone: (877) 466-6669
+Email: [privacycontact@disney.com](mailto:privacycontact@disney.com)
+#### 2\. When Information Collected From Children Is Available To Others
+In addition to those rare instances where a child's personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
+- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
+- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency's (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
+#### 3\. Parental Choices and Controls
+At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
+Where a child has registered for a Disney.com account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
+. Parents can request access to and delete their child's personal information by logging on to the child's account through the Member Services Home Page located [here](). Parents will need their child's username and password. The Your Account home page explains how to recover a password if the child cannot recall it.
+. Parents can contact Guest Services to request access to, change, or delete their child's personal information by sending an email to us at [ms\_support@help.go.com](mailto:ms_support@help.go.com). A valid request to delete personal information will be accommodated within a reasonable time.
+Parents of Club Penguin users may contact Club Penguin directly at:
+Club Penguin
+c/o Disney Canada Inc.
+Dickson Avenue Suite 500
+Kelowna, British Columbia, V1Y 9X1
+CANADA
+Phone: (888) 861-4111 (US and Canada) or +1 (250) 861-5111
+Email: [support@clubpenguin.com](mailto:support@clubpenguin.com)
+Parents of MarvelKids users may contact Marvel directly at:
+W. 50th Street, 7th Floor
+New York, NY 10020
+United States of America
+Phone: +1 (212) 576-4000 (US and Canada)
+Email: [Onlinesupport@Marvel.com](mailto:Onlinesupport@Marvel.com)
+Any other inquiries may be directed to:
+Disney Interactive
+South Buena Vista Street
+Mail Code 7667
+Burbank, CA 91521-7667
+United States of America
+Phone: (877) 466-6669 (US and Canada)
+Email: [privacycontact@disney.com](mailto:privacycontact@disney.com)
+In any correspondence such as e-mail or mail, please include the child's username and the parent's email address and telephone number. To protect children's privacy and security, we will take reasonable steps to help verify a parent's identity before granting access to any personal information.
+© Disney. All rights reserved.
+Email: [privacycontact@twdc.com](mailto:privacycontact@twdc.com)