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.
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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.
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.
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"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your consent, or other lawful means of transferring personal information.— Excerpt from Hulu's Hulu Privacy Policy (Superseded URL)
1. REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V requirements for international transfers of personal data from the EU and UK, which require an adequacy decision, standard contractual clauses, or other approved transfer mechanisms. The UK's post-Brexit international data transfer regime imposes parallel requirements. Brazil's LGPD similarly restricts international transfers to countries with adequate protection or requires contractual safeguards. The policy's reliance on 'reasonable steps' and 'standard contractual clauses where recognized by law' is a standard formulation, though its adequacy depends on implementation. 2. GOVERNANCE EXPOSURE: Medium. The policy's statement that transfer safeguards 'may include' standard contractual clauses introduces conditional language that does not guarantee their use in every transfer scenario. Organizations relying on this policy as the basis for their own international transfer assessments should verify that specific transfer mechanisms are documented for each relevant data flow. 3. JURISDICTION FLAGS: EU and UK users face heightened exposure to transfer-related risks given the volume and diversity of Disney's global operations. Following the Schrems II decision and subsequent developments in EU transfer adequacy, the sufficiency of standard contractual clauses depends on transfer impact assessments that are not described in this policy. 4. CONTRACT AND VENDOR IMPLICATIONS: Data processors and third parties receiving personal data transferred from the EU, UK, or Brazil should confirm that appropriate transfer mechanisms are in place and documented. B2B contracts with Disney or Hulu should specify the transfer mechanism applicable to each data flow. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should maintain a record of international transfer mechanisms in use for each Disney and Hulu data flow, verify that standard contractual clauses are executed with all relevant recipients outside adequate jurisdictions, and confirm that transfer impact assessments are conducted where required. The adequacy of consent as a transfer mechanism for routine large-scale transfers should be evaluated against GDPR guidance, which generally disfavors consent as the basis for systematic international transfers.
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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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