The policy reserves the right to modify its terms and states that material changes will be communicated by email to the last address on file, by posting on Disney sites and applications, or by other means, with consent obtained where required by applicable law.
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
This provision establishes that notice of material policy changes may be delivered to the email address last provided by the user, making the accuracy of contact information on file operationally significant for users who wish to receive change notifications. Consent is stated to be obtained only where required by applicable law, which varies by jurisdiction.
Under this clause, material changes to the privacy policy will be communicated by email to the last address on file, by site or application posting, or by other lawful means, and continued use of Disney services following such notice may constitute acceptance of the revised terms under applicable law. Users who have not maintained a current email address with Disney may not receive direct notice of material changes.
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"From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.— Excerpt from Disney+'s Walt Disney Company Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 13/14 requirements for transparency about processing changes for EU and UK users, CCPA requirements for notice of material privacy policy changes, and general FTC guidance on material change notifications. GDPR may require re-consent or specific notification procedures for changes to processing purposes or legal basis. 2) GOVERNANCE EXPOSURE: Low. The policy's change notification structure is operationally standard for consumer-facing privacy policies. However, the reliance on email to the last address on file and posting on sites as the primary notice mechanisms may not satisfy heightened jurisdiction-specific requirements for certain categories of data processing changes. 3) JURISDICTION FLAGS: EU and UK users may have heightened rights regarding changes to data processing, particularly where changes affect the legal basis for processing or introduce new processing purposes, which may require re-consent under GDPR. California users should be aware that CCPA requires notice before personal information is used for materially different purposes than those originally disclosed. 4) CONTRACT AND VENDOR IMPLICATIONS: Business accounts or partners relying on Disney's data practices should monitor published policy changes, as changes to the privacy policy may affect downstream data processing agreements or consent structures. The provision does not specify a minimum advance notice period before changes take effect. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should establish a monitoring workflow for Disney policy change notifications given the breadth of the policy's application across Disney's service portfolio. Where Disney data flows are incorporated into organizational data maps, policy changes may trigger data mapping update obligations.
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This provision establishes that notice of material policy changes may be delivered to the email address last provided by the user, making the accuracy of contact information on file operationally significant for users who wish to receive change notifications. Consent is stated to be obtained only where required by applicable law, which varies by jurisdiction.
Under this clause, material changes to the privacy policy will be communicated by email to the last address on file, by site or application posting, or by other lawful means, and continued use of Disney services following such notice may constitute acceptance of the revised terms under applicable law. Users who have not maintained a current email address with Disney …
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