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This page describes what the document states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability may vary by jurisdiction. Methodology
This document establishes Hulu's data collection and usage practices across Hulu, Disney+, ESPN+, and other Walt Disney Company services. The policy authorizes the collection of video viewing history, precise geolocation, device identifiers, and behavioral inferences, with provisions permitting cross-platform sharing of this data with third-party advertising partners. The document provides mechanisms for users to opt out of data sales and sharing for targeted advertising purposes through designated privacy choice links.
This document is the Walt Disney Company Privacy Policy governing the collection, use, and sharing of personal information across Disney-owned and operated websites, apps, and services, including Hulu, Disney+, ESPN+, and other affiliated platforms, with stated legal bases including consent, legitimate interests, contractual necessity, and compliance with legal obligations depending on jurisdiction. The policy states that Disney collects a broad range of information including registration data, payment information, precise geolocation, biometric data in certain contexts, viewing and interaction history, device identifiers, and inferences drawn from user behavior, and the terms authorize sharing this data with a wide range of third parties including advertising partners, data analytics vendors, social media platforms, and other Walt Disney Company affiliates for purposes including targeted advertising, content personalization, and business analytics. Notably, the policy discloses that Hulu is subject to the Video Privacy Protection Act (VPPA) and that video viewing records may be disclosed to third parties for advertising and measurement purposes unless users opt out, which represents a material and operationally specific carve-out that consumers should actively manage; the policy also asserts broad rights to process inferred data and combine information across Disney services and third-party sources, creating a cross-platform data profile that may exceed what individual service users reasonably expect. The policy engages the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), GDPR and UK GDPR for European and UK residents, COPPA for users under 13, and the VPPA for video service subscribers, with enforcement authorities including the FTC, California Privacy Protection Agency, EU data protection authorities, and the UK ICO; California residents have explicit opt-out rights for the sale and sharing of personal information for cross-context behavioral advertising, and these rights are exercisable through a dedicated link described in the policy.
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