The policy authorizes sharing of user identifiers and hashed email addresses with third parties for the purpose of delivering and measuring targeted advertising both on Disney and Hulu properties and on third-party sites and applications.
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 advertising-related data sharing extends beyond Disney-owned platforms to third-party sites and applications, and that identifiers and hashed email addresses are shared with external advertising partners for both delivery and measurement of targeted advertising.
Under this clause, Hulu shares user identifiers and hashed email addresses with third-party advertising partners to enable targeted advertising on both Hulu's platforms and external sites and applications; users can opt out of this data sale or sharing through the 'Do Not Sell or Share My Personal Information' control in website footers or application settings.
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"When we provide you with relevant advertising on third-party sites and applications, we may share limited personal information about you, such as certain identifiers or hashed email address, with third parties. We may also share such information to provide you with and to measure relevant third-party advertising on our sites and applications.— Excerpt from Hulu's Hulu Privacy Policy (Superseded URL)
1. REGULATORY LANDSCAPE: This provision engages CCPA and CPRA, which define 'sharing' to include disclosure of personal information for cross-context behavioral advertising and provide California residents with the right to opt out. The FTC's enforcement authority over unfair or deceptive advertising practices is also relevant. EU and UK users are subject to GDPR and the ePrivacy Directive, which impose consent requirements for targeted advertising using cookies and device identifiers. 2. GOVERNANCE EXPOSURE: Medium. The sharing of hashed email addresses and identifiers with third-party advertising partners for cross-site targeting is a widely observed practice, but the breadth of the authorization across third-party sites and applications may require evaluation under CPRA's opt-out right and GDPR's consent requirements for users in those jurisdictions. 3. JURISDICTION FLAGS: California residents hold a statutory opt-out right under CPRA for sharing of personal information for cross-context behavioral advertising. EU and UK users require a lawful basis, typically consent, for processing of personal data for targeted advertising using cookies or identifiers. The document references opt-out controls in website footers and application settings as the mechanism for exercising these rights. 4. CONTRACT AND VENDOR IMPLICATIONS: Third-party advertising and measurement partners receiving identifiers and hashed email addresses from Hulu should be assessed as to their own data processing practices and whether their use of received data is restricted to the purposes stated in this policy. Data processing agreements with advertising partners should be reviewed for consistency with the policy's representations. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the opt-out mechanism provided in website footers and application settings is technically functional and effective for suppressing identifier sharing with advertising partners. The policy references the Online Tracking Technologies and Advertising page for further detail; that supplemental page should be reviewed as part of any compliance assessment. Cookie consent mechanisms for EU and UK users should be audited to confirm they satisfy the applicable consent standard before identifier sharing is initiated.
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This provision establishes that advertising-related data sharing extends beyond Disney-owned platforms to third-party sites and applications, and that identifiers and hashed email addresses are shared with external advertising partners for both delivery and measurement of targeted advertising.
Under this clause, Hulu shares user identifiers and hashed email addresses with third-party advertising partners to enable targeted advertising on both Hulu's platforms and external sites and applications; users can opt out of this data sale or sharing through the 'Do Not Sell or Share My Personal Information' control in website footers or application settings.
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