Disney says it will not collect personal data from children under 13 without a parent's verified consent, and will not sell or share data from 13-16 year olds without their opt-in agreement.
This analysis describes what Disney+'s agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Families using Disney+ and other Disney services should understand that children's accounts and family profiles may involve data collection about minors, and the adequacy of age verification and parental consent mechanisms is critical to whether these protections function in practice.
Interpretive note: The policy's protections depend on the effectiveness of Disney's age-verification and account-gating mechanisms, which are not described in detail in the policy text; actual compliance depends on operational implementation that cannot be assessed from the policy alone.
Parents whose children use Disney services should verify that age settings and parental controls are correctly configured, as the policy's protections for under-13 users depend on proper account setup and Disney's implementation of age-gating mechanisms.
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YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.
Our services are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If we become aware that we have collected personal information from a child under the age of 13 without parental consent, we wil...
Our online services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete that information as quickly as possible.
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"We do not knowingly collect personal information from children under 13 without first obtaining verifiable parental consent as required by applicable law. For children between the ages of 13 and 16, we do not knowingly sell or share their personal information without first obtaining opt-in consent from the child. If you believe that we have collected information from your child without your consent, please contact us at privacy@disney.com.— Excerpt from Disney+'s Disney Privacy Policy
REGULATORY LANDSCAPE: This provision directly implicates COPPA, which requires verifiable parental consent before collecting personal information from children under 13 and is enforced by the FTC. The FTC has brought multiple high-profile COPPA enforcement actions against streaming and entertainment platforms. CPRA additionally grants opt-in consent rights for 13-16 year olds regarding sale and sharing of their personal data. EU/EEA users are subject to GDPR Article 8, which sets age of consent for data processing at 16 (with member state discretion to lower to 13), requiring parental consent for younger users. GOVERNANCE EXPOSURE: High. COPPA compliance for a platform like Disney that offers family-oriented content is a documented FTC enforcement priority. The policy's statement that Disney does not 'knowingly' collect children's data without parental consent places significant weight on the effectiveness of age-verification and account-gating mechanisms, which are not described in detail in the policy text itself. JURISDICTION FLAGS: COPPA applies to all US users under 13. CPRA's 13-16 opt-in consent requirement applies to California residents. GDPR Article 8 applies to EU/EEA users with age thresholds varying by member state (13-16). UK GDPR and the Age Appropriate Design Code (Children's Code) impose additional obligations for UK users under 18, requiring privacy by default and data minimization for child users. CONTRACT AND VENDOR IMPLICATIONS: Any third-party service providers with access to data collected through family accounts or children's profiles must be governed by COPPA-compliant data processing agreements. Vendors providing advertising or analytics services should be restricted from receiving children's data. COMPLIANCE CONSIDERATIONS: Legal teams should audit the technical implementation of age-gating across all Disney services to verify that under-13 users cannot access full data collection features without verifiable parental consent; review parental consent mechanisms for COPPA adequacy (particularly 'verifiable parental consent' methods); assess whether the UK Children's Code requirements for privacy by default are implemented for users under 18 in the UK; and confirm that data minimization principles are applied to children's accounts across all Disney platforms.
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Families using Disney+ and other Disney services should understand that children's accounts and family profiles may involve data collection about minors, and the adequacy of age verification and parental consent mechanisms is critical to whether these protections function in practice.
Parents whose children use Disney services should verify that age settings and parental controls are correctly configured, as the policy's protections for under-13 users depend on proper account setup and Disney's implementation of age-gating mechanisms.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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