Disney+ · Disney Privacy Policy · View original document ↗

Data Sharing with Affiliates and Business Partners

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Disney can share your personal information across all its affiliated companies and with business partners for promotions and other purposes, as well as with service providers who handle data on Disney's behalf.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Sharing data across Disney's full family of companies, which includes ABC, ESPN, Hulu, Marvel, Lucasfilm, and others, means data collected in one context can be used in many others without requiring separate consent for each entity.

Consumer impact (what this means for users)

Personal information you provide to Disney+ may be shared with other Disney-owned companies and business partners for promotional and advertising purposes, broadening the reach of your data beyond the specific service you enrolled in.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Visit the Disney 'Do Not Sell or Share My Personal Information' page and complete the opt-out form to restrict sharing of your data with business partners for advertising purposes.

How other platforms handle this

HubSpot Medium

We may share your personal data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We may also share your personal data with advertising partners to display relevant advertising to y...

Steam Medium

In order to provide you with services, Valve needs to share some data with the publisher or developer of the game (for example to verify your ownership of the game and register your Steam ID with the publisher), or with other third parties that Valve works with to provide services to you. Valve will...

Zoom Medium

Zoom may share personal data with third-party advertising partners and analytics providers to deliver targeted advertising and measure the effectiveness of advertising campaigns. This may include sharing identifiers, device information, and behavioral data with partners such as advertising networks.

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share information about you within The Walt Disney Company family of companies (Affiliates) and with our business partners so that they can send you promotional communications, and for other purposes set out in this Privacy Policy. We may also share your information with service providers that perform services on our behalf, including data analytics companies, advertising companies, payment processors, and other service providers.

— Excerpt from Disney+'s Disney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Intra-group data sharing across affiliated companies engages GDPR's data controller and data processor framework for EU/EEA users; each affiliate receiving personal data as a controller must have an independent lawful basis for processing. CCPA and CPRA treat affiliated companies as separate businesses for purposes of sale and sharing disclosures in some contexts. The FTC's jurisdiction covers deceptive practices related to data sharing representations. GOVERNANCE EXPOSURE: Medium. The policy's authorization of broad sharing across Disney's affiliate network and with 'business partners' for promotional purposes is a common industry practice, but the breadth of Disney's affiliate network creates operational complexity in ensuring consistent privacy standards across all entities receiving data. The distinction between service providers (who act on Disney's behalf) and business partners (who may be independent controllers) is significant under CCPA and CPRA. JURISDICTION FLAGS: EU/EEA users require that each Disney affiliate receiving their data has an independent lawful basis for processing under GDPR. California residents have the right to know about and opt out of sharing with business partners where such sharing qualifies as a 'sale' or 'sharing' under CPRA. Cross-border transfers to affiliates outside the EEA require Standard Contractual Clauses or equivalent transfer mechanisms. CONTRACT AND VENDOR IMPLICATIONS: B2B partners receiving data under this provision should be assessed to determine whether they qualify as processors or independent controllers. Service provider agreements should include CCPA-compliant provisions restricting use of data to specified business purposes. Affiliate data sharing agreements should be reviewed for GDPR adequacy. COMPLIANCE CONSIDERATIONS: Compliance teams should maintain an up-to-date record of all affiliates and business partners receiving personal data; verify that intra-group data transfers comply with GDPR transfer requirements; confirm that the CPRA distinction between service providers, contractors, and third parties is accurately reflected in data sharing agreements; and review whether promotional communications sent on behalf of affiliates comply with applicable marketing consent requirements.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has enforcement authority over unfair or deceptive data sharing practices including affiliate and business partner data flows that may not align with consumer expectations.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Disney Privacy Policy
Entity
Disney+
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 10, 2026
Record ID
CA-P-009493
Document ID
CA-D-00575
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1cc10681f97c3f090eedf7305d800f793a730ca3d2e27b50833ec244773b34eb
Analysis generated
May 8, 2026 08:25 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Disney+
Document: Disney Privacy Policy
Record ID: CA-P-009493
Captured: 2026-05-08 08:25:00 UTC
SHA-256: 1cc10681f97c3f09…
URL: https://conductatlas.com/platform/disney/disney-privacy-policy/data-sharing-with-affiliates-and-business-partners/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Disney+'s Data Sharing with Affiliates and Business Partners clause do?

Sharing data across Disney's full family of companies, which includes ABC, ESPN, Hulu, Marvel, Lucasfilm, and others, means data collected in one context can be used in many others without requiring separate consent for each entity.

How does this clause affect you?

Personal information you provide to Disney+ may be shared with other Disney-owned companies and business partners for promotional and advertising purposes, broadening the reach of your data beyond the specific service you enrolled in.

Is ConductAtlas affiliated with Disney+?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Disney+.