The policy states that when Disney and Hulu intend to collect personal information from children, they notify parents, obtain parental consent in accordance with applicable law, limit collection to what is reasonably necessary, and provide parents with access and deletion rights over their children's personal information.
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This provision establishes the framework for children's data collection compliance, referencing COPPA-aligned parental notification, consent, data minimization, and parental access and deletion rights, with a reference to a separate Children's Privacy Policy for US-specific detail.
Under this clause, parents or legal guardians are entitled to notice of data collection practices applicable to their children, parental consent is required before personal information is collected from children for certain activities, and parents may request access to, correction of, or deletion of their children's personal information through Guest Services.
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"When we intend to collect personal information from children, we take additional steps to protect children's privacy, including: Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information; In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children; Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.— Excerpt from Hulu's Hulu Privacy Policy (Superseded URL)
1. REGULATORY LANDSCAPE: This provision directly engages the Children's Online Privacy Protection Act, enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13 in the United States. The policy references a separate Children's Privacy Policy for US-specific detail. GDPR and UK GDPR impose similar requirements for children's data, with the age of consent varying by EU member state (13 to 16 years). State-level children's privacy laws, including California's Age-Appropriate Design Code, may impose additional requirements for services likely to be accessed by minors. 2. GOVERNANCE EXPOSURE: Medium. The breadth of Disney's and Hulu's service portfolio, spanning streaming, theme parks, gaming, and consumer products, creates significant surface area for children's data collection across multiple platforms. The policy's description of age-gating for certain features and separate parental consent procedures for children's data collection requires ongoing operational verification that age-gating mechanisms are technically effective. 3. JURISDICTION FLAGS: US operations are subject to COPPA's strict parental consent requirements for children under 13. California's Age-Appropriate Design Code creates additional obligations for services likely to be accessed by users under 18. EU member states with consent ages above 13 may require parental consent for users in older age brackets. The policy references a separate Children's Privacy Policy for the United States, which should be reviewed independently. 4. CONTRACT AND VENDOR IMPLICATIONS: Third-party partners who receive data from Disney or Hulu platforms that may include children's data should be assessed for COPPA compliance. Content programmers, device partners, and advertising partners receiving Hulu data should confirm their practices with respect to data associated with child accounts. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that age-gating mechanisms are technically robust and that parental consent flows for children's features satisfy COPPA's verifiable parental consent standard. The separate Children's Privacy Policy referenced in this document should be reviewed for consistency with this overarching policy. Parental access and deletion request procedures should be documented and tested to confirm operational readiness.
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This provision establishes the framework for children's data collection compliance, referencing COPPA-aligned parental notification, consent, data minimization, and parental access and deletion rights, with a reference to a separate Children's Privacy Policy for US-specific detail.
Under this clause, parents or legal guardians are entitled to notice of data collection practices applicable to their children, parental consent is required before personal information is collected from children for certain activities, and parents may request access to, correction of, or deletion of their children's personal information through Guest Services.
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