The policy states that personal information may be transferred to Disney family members or third parties in locations around the world, and that the company will take reasonable steps to safeguard privacy including implementing standard contractual clauses, obtaining consent, or using other lawful transfer mechanisms.
This analysis describes what Hulu'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 Hulu and Disney rely on standard contractual clauses, consent, or other lawful means as the legal basis for international personal data transfers, which is operationally significant for EU and UK users whose data may be transferred to the United States or other jurisdictions without an adequacy decision.
Interpretive note: The policy uses conditional language ('may include') for transfer safeguards rather than stating definitively that standard contractual clauses are used in all applicable transfers, creating ambiguity about compliance for specific data flows.
Under this clause, personal information collected from users in any geography may be transferred to and processed by Disney entities or third parties located in other countries, with the company stating it will implement standard contractual clauses or other recognized transfer mechanisms as applicable to safeguard that data.
Cross-platform context
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Compare across platforms →"We operate globally and may transfer your personal information to individual companies of The Walt Disney Family of Companies or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information.Excerpt from Hulu's Privacy Policy (Superseded URL) [RETIRED: redirects to the Walt Disney privacy center (CA-D-000575)]
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This provision establishes that Hulu and Disney rely on standard contractual clauses, consent, or other lawful means as the legal basis for international personal data transfers, which is operationally significant for EU and UK users whose data may be transferred to the United States or other jurisdictions without an adequacy decision.
Under this clause, personal information collected from users in any geography may be transferred to and processed by Disney entities or third parties located in other countries, with the company stating it will implement standard contractual clauses or other recognized transfer mechanisms as applicable to safeguard that data.
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