THE WALT DISNEY COMPANY PRIVACY POLICY FOR NON-GUEST RELATIONSHIPS

Last Updated: 7/24/2023

The Walt Disney Family of Companies (“we” or “us” or “our” or “Disney”, and defined more fully below) values your trust and is committed to the responsible management, use, and protection of Personal Information. Personal Information (defined more fully below) is any information that identifies (whether directly or indirectly) a particular individual. This privacy policy applies to non-guest relationships, such as with job applicants and third party businesses, and describes our collection, use, and storage of Personal Information on the sites and applications where this privacy policy is posted. This privacy policy does not apply to our processing of guest information provided or collected where our Global Privacy Policy is posted. This privacy policy also does not apply to employee data processed in accordance with an applicable employee privacy notice. If you have been provided with another Disney privacy notice in connection with your business relationship with us, such notice still applies and should be read in conjunction with this privacy policy, which specifically applies to your use of the site or application on which this privacy policy is posted.

California Notice at Collection of Personal Information:

If you are a California Resident, we may collect the Personal Information listed below under “Information We Collect,” for the purposes listed below under “Use of Information.” Please also see additional disclosures and a description of your privacy rights below under “Additional Disclosures for California Residents.” We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by applicable law, or unless otherwise stated elsewhere in this privacy policy or any other privacy disclosure provided to you.

Table of Contents

WHO WE ARE.. 2

INFORMATION WE COLLECT.. 2

USE OF INFORMATION.. 8

DISCLOSURE OF PERSONAL INFORMATION.. 9

DATA RETENTION.. 9

SECURITY.. 10

LINKS TO THIRD-PARTY WEBSITES.. 10

DATA TRANSFERS AND APPLICABLE LAW... 10

CHANGES TO THIS PRIVACY NOTICE.. 10

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS.. 11

ADDITIONAL DISCLOSURES FOR UK & EU RESIDENTS.. 15

ADDITIONAL DISCLOSURES FOR CHINA RESIDENTS.. 17

DEFINITIONS.. 18

WHO WE ARE

A member of The Walt Disney Family of Companies, which includes many different brands, will be the Data Controller of your information under this privacy policy. The member of The Walt Disney Family of Companies that is the Data Controller for your information can be found below. The Data Controller is responsible for and may use your Personal Information for the purposes described in this privacy policy. Other members of The Walt Disney Family of Companies may have access to your information where they perform services on behalf of the Data Controller(s) (as a Data Processor), and unless prohibited under applicable law, for use on their own behalf (as a Data Controller) for the purposes described in this privacy policy.

INFORMATION WE COLLECT

Information You Provide

We may collect your Personal Information and Anonymous Information which is relevant to our business or potential professional relationship with you or our business relationship with your company. The Personal Information we collect may include:

registration information you provide when you create an account, or link your profile on a third-party site or platform with your registration account, such as your first name, username and password, country of residence, gender, date of birth, and email address;
information in connection with your marketing, sales or other commercial activity;
information sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where we are permitted by applicable law to collect this information;
information in connection with an employment application, including contact information, work authorization status, government issued identification, CV/resume, previous work experience, education information, skills, references, work-related licenses, permits, certifications, any other information you elect to provide to us (e.g., awards or professional memberships, or diversity & inclusion information);
diversity & inclusion information regarding a business, supplier, or company leadership;
information generated during an interview and/or any written assessments (when applicable) in connection with a job application, including but not limited to your image, video or voice information captured by web conferencing tools, CCTV, and security cameras;
information about you submitted during a competition such as prize draws available to our trade partners, not to guests or members of the public (e.g., Spin to Win);
information about you from third parties or public sources as necessary to support the job recruitment process, including, without limitation, background, educational, work performance, credit and criminal record checks (only to the extent permitted by law);
financial account information that you provide when setting up payroll direct deposit, expense reimbursement, or otherwise engaging a financial transaction;
location information (including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address) where we are permitted by law to process this information;
activity information about your use of our sites and applications, such as the content you view or post, any surveys you participate in, how often you use our services, and your preferences; and
usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address; and

If you are a job applicant, we may collect Personal Information directly from you, from entities authorized by you (such as third-party job search platforms, recruitment or headhunting agencies) or from other third parties (such as background check agencies). Please note that if you submit a job application to us through a third-party job search platform, headhunting or job placement agency, the privacy policy of such third party shall apply to your provision of Personal Information to such third party.

USE OF INFORMATION

As noted above, the member of The Walt Disney Family of Companies that is the Data Controller for your information is responsible for and may use your information for the purposes described in this privacy policy. Other members of The Walt Disney Family of Companies may have access to your information where they perform services on behalf of the Data Controller (as a Data Processor) and, unless prohibited under applicable law, for use on their own behalf (as a Data Controller) for the purposes described in this privacy policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, for our business purposes, including to:

manage our relationship with you;
communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies;
improve and develop our services, including personalizing content and experiences;
manage our suppliers, distributors, independent contractors, service providers, and others throughout the supply and distribution chain;
operate and manage our businesses;
provide your clients with services and products;
organize and implement tasks in preparation of or to perform existing contracts;
evaluate activities at our facilities, including compliance with applicable policies, as well as with health and safety rules in place;
grant you access to our training and collaboration modules allowing you access to certain materials and services you are entitled to receive;
manage and support our IT resources, including infrastructure management and business continuity;
manage diversity information;
collect, store, and analyze survey responses;
preserve our economic interests and ensure compliance and reporting (such as complying with our policies and local legal requirements, tax and deductions, conducting audits, responding to complaints, and defending litigation);
archiving and record-keeping;
If you are a job applicant, manage your job application process, including any interview(s) and written assessments;
If you are a job applicant, evaluate your job application including your skills, qualifications and background, verify your information and conduct reference checks or background checks, make arrangements for your future employment; and
If you are a job applicant, manage and improve our recruitment and hiring process.

SHARING YOUR INFORMATION WITH OTHER ENTITIES

We will not share your personal information with a third party outside The Walt Disney Family of Companies except in limited circumstances, including:

When you direct us to share your personal information with another company to fulfill your request (e.g., when you direct us to share information with another company for health benefits);
When companies perform services on our behalf, like package delivery; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and
When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests, employees, and third parties, to protect our rights and property and the rights and property of our guests, employees, and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

Please note that once we share your personal information with another company in some of the above circumstances, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.

LEGAL REMEDIES AND REGULATORY COMPLIANCE

In addition, we will use your information as permitted by local law to protect our rights, including to:

enforce this privacy policy and our terms and conditions;
monitor your use of our sites and applications, and otherwise ensure the privacy and safety of such sites and applications, our property, and that of our affiliates, you or others; and
to allow us to pursue available remedies or limit the damages that we may sustain.

Where required, we will use such information to:

comply with or evaluate compliance with any applicable law or regulation; and
respond to requests from public and government authorities, including public and government authorities outside your country of residence.

CORPORATE TRANSACTIONS

Your Personal Information may be used by us to complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our businesses, assets, or stock (including in connection with any bankruptcy or similar proceedings).

DISCLOSURE OF INFORMATION

We may share Personal Information within The Walt Disney Family of Companies for the purposes described in this privacy policy. The obligations which are set out in this privacy policy shall apply to other members of The Walt Disney Family of Companies to the same extent that they apply to the Data Controller of your Personal Information. In the course of our activities and for the same purposes as those listed in this privacy policy, your Personal Information can also be accessed by or transferred to the following categories of recipients as needed to achieve such purpose:

our banks and other payment processing service providers;
our IT systems providers, cloud service providers, database providers, and consultants;
our other suppliers, distributors, and service providers that provide services and products to us;
organizations that we believe you are employed by or work with, whether under contract or otherwise, and any affiliates or other related entities of such organization;
our professional service providers, such as accountants, auditors, legal advisors, and insurance brokers;
our archive storage providers; and
other third parties or entities as disclosed in this privacy policy or as permitted or required by law.

We may analyze your information in aggregate form in the course of our activities and for the same purposes as those listed in this privacy policy. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and current and prospective business partners and to other third parties for other lawful purposes.

DATA RETENTION

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by applicable law, or unless otherwise stated elsewhere in this privacy policy or any other privacy disclosure provided to you.

SECURITY

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented appropriate technical, administrative, organizational, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our reasonable efforts, no security measures are perfect or impenetrable.

Online Tracking Technologies and Advertising

About Online Tracking Technologies and Advertising

We and certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you, on our sites and applications using tracking technologies such as browser cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons. This tracking data may be used for many purposes including, for example, to:

provide useful features to simplify your experience when you return to our sites and applications (for example, remembering your language preference);
deliver relevant content based on your preferences, usage patterns, and location;
monitor, evaluate, and optimize the use and operation of our sites and applications; and
analyze traffic on our sites and on the sites of third parties.

We may collect information whether or not you are logged in or registered, and may associate this tracking data with your registration account (if you have one), in which case we will treat it as personal information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.

Advertisers and third parties also may collect information about your activity on our sites and applications, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our sites and applications and on third-party sites and applications.

Types of Online Tracking Technologies

Examples of online tracking technologies include:

Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your device warn you each time a cookie is being placed on your device, or you can choose to block all cookies. You do this through your browser settings and/or depending on the website you are visiting, you may also be able to manage your cookies settings via a link in the footer of the website, if applicable. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your user experience more efficient, and some of our services will not function properly.
Web beacons and marketing pixels. Web beacons and marketing pixels are small pieces of data that are embedded in images on the pages of sites. They may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use web beacons or marketing pixels to bring together information we collect about you.

Do Not Track

You or your authorized agent may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

LINKS TO THIRD-PARTY WEBSITES

Our sites may contain links to other websites. This privacy policy does not address, and we are not responsible for, the privacy, information security, or other practices of any third parties, including any third party operating any website or service to which our sites link. Privacy choices you have made on third party websites or services will not apply to our use of the information we have collected directly through our sites and offline. We encourage you to be aware when you leave our sites and to read the legal notices posted on other sites, including their privacy policies.

DATA TRANSFERS AND APPLICABLE LAW

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. Additionally, when using or disclosing Personal Information transferred from the European Union, United Kingdom, or Switzerland, we use Standard Contractual Clauses approved by the European Commission (EU) or Information Commissioner’s Office (UK), adopt other means under relevant data protection laws for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of the Standard Contractual Clauses when transferring Personal Information from Australia and Argentina.

CHANGES TO THIS PRIVACY NOTICE

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

CONTACT US

If you have questions about this privacy policy, please contact us by e-mail at: CORP.Disney.Privacy.Team@disney.com. Also, please continue below for contact information relevant to your region. If you are not satisfied with a reply received from us, you may at any time refer your complaint to the relevant regulator in your jurisdiction.

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

This notice to California residents is provided under California law. This notice explains your privacy rights if you are a California resident, providing our “notice at collection,” and providing certain mandated disclosures about our treatment of California residents’ information, both online and offline.

NOTICE OF COLLECTION

We may collect these categories of personal information when you interact with us: identifiers/contact information, demographic information (such as gender and age), financial account information commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.

We collect this information so that we can best serve you, including to fulfill your requests A more detailed description of these purposes is in the USE OF INFORMATION section of this privacy policy.

California residents also have the right to “opt out” of the “sale” or “sharing” of their “personal information” to “third parties” (as those terms are defined under law).

CALIFORNIA MANDATORY DISCLOSURES

We also make the following disclosures for purposes of compliance with California privacy law:

We collected the following categories of personal information in the last 12 months: identifiers/contact information, demographic information (such as gender and age), financial account information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
The sources from whom we collected personal information are: directly from our employees, our contractors, third-party sites or platforms that you link with your registration account, analytics tools, social networks, and third-party services that update or supplement information we hold about you.
The business or commercial purposes of collecting personal information are as summarized in our “notice at collection” section, and as described in more detail in this privacy policy under “USE OF INFORMATION.”
We disclosed the following categories of personal information for a business purpose in the last 12 months: identifiers/contact information, demographic information (such as gender and age), financial account information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “Sharing Your Personal Information with Other Entities” section of this privacy policy.
As the term is defined by applicable law, we “sold” or “shared” the following categories of personal information in the last 12 months: identifiers/contact information, Internet or other electronic network activity information, and inferences drawn from the above. We “sold” or “shared” each category to or with data analytics providers and social networks.
The business or commercial purposes of “selling” or “sharing” personal information is for third-party companies to perform services on our behalf.
We do not “sell” or “share” personal information of known minors under 16 years of age.

CALIFORNIA RESIDENTS’ RIGHTS

Right to Access

If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

Right to Delete

If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

Right to Request Correction

If you are a California resident, you have the right to request that we correct inaccurate Personal Information that we maintain about you, subject to certain exceptions. Once we receive and verify your request, we will process your correction request in accordance with California law.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to “opt out” of the “sale” or “sharing” of your “personal information” to “third parties” (as those terms are defined by applicable law).

Right of Non-Discrimination

We will not discriminate against you for exercising any of your rights, including, but not limited to denying you products or services; charging you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties; providing you a different level or quality of products or services; suggesting that you may receive a different price or rate for products or services or a different level or quality of products or services.

Sensitive Personal Information

While we collect Sensitive Personal Information as described in this policy, we do not use this information for the purpose of inferring characteristics about you; and limit our use of such information to business purposes.

Exercising Rights to Know, Access, Correction or Deletion

To exercise your privacy rights, please submit a verifiable request to us by either: (a) calling us at (877) 466-6669 or (b) submitting your request by completing the California DSAR Form. We may request additional documentation or information solely for the purpose of verifying your identity.

Instructions for Authorized Agents Making Access and Deletion Requests

You may also use an authorized agent to submit an access, deletion or correction request on your behalf. Authorized agents may submit such requests using the Authorized Agent Request Form . An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.

Making Requests to “Opt Out” of the “Sale” or “Sharing” of “Personal Information”

To submit a request to opt out of the sale or sharing of your personal information, you may visit our “Do Not Sell or Share My Personal Information” Rights page or send an email to caprivacy@twdc.com with the subject line “do not sell or share info.” You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so. Authorized agents may submit requests to opt out by using the Authorized Agent Request Form. You have the right not to receive discriminatory treatment for the exercise of your privacy rights.

CALIFORNIA PRIVACY RIGHTS METRICS

For California privacy rights metrics, please refer to the to the California Privacy Rights Metrics section of the Your US Privacy Rights page.

CONTACT INFORMATION

If you have a question about our privacy policies, please send an email to caprivacy@twdc.com or write us at:

CA Privacy Rights

Disney Interactive Media Group

500 South Buena Vista Street

Mail Code 7667

Burbank, CA 91521-7667

ADDITIONAL DISCLOSURES FOR UK & EU RESIDENTS

DATA CONTROLLERS

The Data Controller of your Personal Information, is the relevant entity within The Walt Disney Family of Companies which your relationship is with. By way of example, if you are a job applicant, the Data Controller is the entity which the job is with. And if you or your company has a business relationship with Disney, the Data Controller is the entity which has engaged you or your company.

For applicants or business relationships with Disneyland Paris, the Data Controller is: Euro Disney Associés SAS, 1 rue de la Galmy, 77700 Chessy, France.

LAWFUL BASIS FOR UK & EU RESIDENTS

If you are resident in the UK or the EU, our lawful bases for processing your Personal Information under this privacy policy include:

statutory obligation: for example when we collect information pertaining to an incident on-site pertaining to a non-employee; in complying and reporting as legally required;
contract: for example, where you / your business is supplying services to a member of the Walt Disney Family of Companies; when you enter a competition; or, when on-boarding job applicants;
consent: for example, when you submit a job application to a UK or EU entity within The Walt Disney Family of Companies; when personalizing content and experiences; or when collecting diversity information; and
legitimate interest: our legitimate interests when balanced against your rights, such as the use of data analytics to review and better understand employee application rates; or, to prevent fraud; to request feedback from you about features on our site or applications via surveys; to communicate with our commercial partners or organisations we think would like to hear from us about events, training or business announcements.

ACCESS AND CORRECTION

Certain sites and applications we provide may permit you to access, review, and change your Personal Information by logging in and updating your account information. Please note that if you change or correct account information after submitting it, such changes will be visible to us.

Apart from account information, you may request access to your Personal Information that we collect, or you may request its modification, correction, or deletion, where permitted by applicable law. If you are resident in the UK or EU, you may also have the right to oppose the processing of your Personal Information where the lawful basis relied on is our legitimate interests. Please contact us at DataProtection@disney.co.uk to exercise any of these rights.

For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before responding to your request. We will try to comply with your request as soon as reasonably practicable. Please note that certain Personal Information may be exempt from such access, correction, or suppression rights pursuant to local data protection laws.

To review our Cookie policy, please visit https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/cookies-policy/.

ADDITIONAL CONTACT INFORMATION

If you are a resident of the UK or the EU, you may:

Contact our Data Protection Office at DataProtection@disney.co.uk with any questions about this privacy policy;

lodge a complaint with a data protection authority for your country or region or in the place of the alleged misconduct. The ICO in the UK can be contacted by visiting ico.org.uk, or, to contact a data protection authority in the EU, please visit here.
If the relevant Data Controller is Euro Disney Associés SAS (see above), for example if you are a job applicant or your business relationship is with Disneyland Paris, you can contact:dlp-donneesperso-cm@disney.com to exercise any rights listed in this privacy policy; or
lodge a complaint with the CNIL, by visiting https://www.cnil.fr/.

ADDITIONAL DISCLOSURES FOR CHINA RESIDENTS

This Privacy Policy describes the collection, use, sharing, transfer, storage and processing of Personal Information on the sites and applications where this privacy policy is posted (insofar as mainland China is concerned, such sites and applications include, without limitation, chinajobs.disneycareers.cn site, shdr.disneycareers.cn site, Disney China Recruitment (迪士尼Disney中国招聘, ID “Disney Recruitment”) WeChat Public Account, Shanghai Disney Resort Job Opportunities (上海迪士尼度假区工作, ID “SHDRjob”) WeChat Public Account. For the purpose of this privacy policy, “China” or “mainland China” refers solely to the mainland of the People’s Republic of China, and does not include Hong Kong, Macao and Taiwan.

The Data Controller with respect to your Personal Information shall be the employer of the position for which you apply (if you are a job applicant) or the Disney entity with which you (or the company for which you work) have a contractual or other business relationship; namely, The Walt Disney Company (China) Limited, Shanghai International Theme Park Company Limited, Shanghai International Theme Park Associated Facilities Company Limited, Shanghai International Theme Park And Resort Management Company Limited, or any other members of The Walt Disney Family of Companies in China, as the case may be.

LEGAL BASIS FOR PROCESSING

We process your Personal Information based on your consent and/or as necessary for the performance of our statutory duties or legal obligations.

DATA TRANSFER

To the extent permitted by applicable law, we may share Personal Information (the types of which are set out in the INFORMATION WE COLLECT section of this privacy policy) with members of The Walt Disney Family of Companies located inside and outside of mainland China for the purposes described in the USE OF INFORMATION section of this privacy policy. We will make the information available to personnel with a need to know the information for the purposes described in this privacy policy. The list of relevant recipients are as follows:

P0001-(TXT)Company Code	Address	Phone Number	Country
WD Parks & Resorts US,Inc	1375 Buena Vista Drive 4th Floor North Lake Buena Vista FL 32830	(407) 824-2222	United States
ABC Inc.	77 West 66th Street New York NY 10023 USA	(800) 230-0229	United States
Disney Worldwide Services, Inc.	1375 Buena Vista Drive P.O. Box 10000 Lake Buena Vista FL 32830 USA	(818) 560-1000	United States
DVC Management LLC.	215 Celebration Place Suite 300 Celebration FL 34747 United States	(407) 566-3100	United States
ESPN, Inc	ESPN Plaza 935 Middle Street Bristol CT 06010-7454	(860) 766-2000	United States
TWDC Enterprises 18 Corp.	500 South Buena Vista Street Burbank CA 91521	(818) 560-1000	United States
Magical Cruise Co, Ltd	3 Queen Caroline Street Hammersmith, London, W6 9PE United Kingdom	+44-2082221000	UK
Disney HR Srvcs	500 South Buena Vista Street Burbank CA 91521 USA	(321) 939-7000	United States
Disney Fincl Svcs	500 South Buena Vista Street Burbank CA 91521 USA	(619) 670-9400	United States
DCPI, Inc.	500 South Buena Vista Street Burbank CA 91521 USA	(818) 544-0000	United States
The Walt Disney Co. Ltd	3 Queen Caroline Street Hammersmith, London, W6 9PE United Kingdom	+44-2082221000	UK
TWDC (Germany) GmbH	Industriegebiet Süd c/o Meyer Werft, 26871 Papenburg Germany	+49-89993400	Germany
Disney Middle East FZ-LLC	47th Floor, Block B Business Central Towers Dubai Media City Dubai United Arab Emirates	+44-2082221000	UAE
01 Euro Disney Associes	1 rue de la Galmy Chessy 77700 Chessy France	+33-164744000	France
TWDC (Hong Kong) Ltd.	38/F, Oxford House, Taikoo Place 979 King's Road Quarry Bay Hong Kong	+852-22032000	Hong Kong
TWDC (Japan) Ltd.	Toranomon Hills Mori Tower 1-23-1 Toranomon Minato-ku Tokyo 105-6355 Japan	+81-367522300	Japan
TWDC (China) Ltd	6/F Link Square 1 222 Hu Bin Road Shanghai 200021 China	+86 2123161002	China
UTV Software Comm Pvt Ltd	Star House, Urmi Estate 95 Ganpatrao Kadam Marg Lower Parel (West) Mumbai 400013 India	+91 22 6630 5555	India
Disney Streaming Ops LLC	500 South Buena Vista Street Burbank CA 91521 USA	(818) 560-1000	United States
WPVI TELEVISION, LLC	77 West 66th Street New York NY 10023	(609) 344-6661	United States
Disney Corp Srvcs Co, LLC	500 South Buena Vista Street Burbank CA 91521 USA	(818) 560-1000	United States
HK Intl Theme Parks Ltd.	Hong Kong Disneyland Resort Lantau Island Hong Kong	+852-35503369	Hong Kong

In any case, we will only share your Personal Information for specific purposes based on the principles of lawfulness, legitimacy, necessity, and good faith, and only share Personal Information to the extent necessary to achieve the relevant purposes or fulfill our statutory obligations.

When we conduct cross-border transfers of Personal Information, we will protect such information as described in this privacy policy as disclosed to you at the time of data collection, and will always comply with the requirements under applicable laws.

YOUR STATUTORY RIGHTS AS A DATA SUBJECT

You may request access to and make a copy of your Personal Information that we collect, correct inaccurate or incomplete Personal Information concerning you, delete your Personal Information in certain circumstances, withdraw your consent previously given to certain types of our processing activities with future effect, transfer your Personal Information we hold to another Data Controller designated by you if the relevant requirements are fulfilled, request an explanation of our rules of processing Personal Information, where permitted and to the extent required by applicable law.

If you are a job applicant, please note that if you request to delete your Personal Information or withdraw your consent, we may not be able to continue processing your job application.

We will try to comply with your request as soon as reasonably practicable, within the statutorily required timeline.

Please note that certain Personal Information may be exempt from such access, correction, or suppression rights pursuant to local data protection laws.

CONTACT INFORMATION

If you have questions or requests related to this privacy policy, please feel free to contact us as follows:

Job applicants for The Walt Disney Company (China) Limited: twdc.ta.cn@disney.com

Job applicants for Shanghai International Theme Park Company Limited, Shanghai International Theme Park Associated Facilities Company Limited or Shanghai International Theme Park And Resort Management Company Limited,: SHDR.JOBS@disney.com.

You also have the right to lodge any complaint related to data protection with the relevant regulator.

ADDITIONAL DISCLOSURES FOR COLOMBIA Residents

Data Controllers

The Data Controller is the subsidiary or affiliate of The Walt Disney Company that is responsible for the Personal Information collected and used within the scope of this Privacy Notice from our sites and applications, as follows:

For Colombia, the Controllers will be:

TFCF CHANNELS COLOMBIA LTDA,

Tax ID No. 830.140.775-0

Carrera 50 No. 17 -77 Bogotá D.C., Colombia

Phone +57 6107044

Email: LATAM.Privacidad@disney.com

ESPN COLOMBIA S.A.S.,

Tax ID No. 900.631.238-8

Calle 90 No. 19A – 46 Bogotá D.C., Colombia

Phone +57 5961242

Email: LATAM.Privacidad@disney.com

THE WALT DISNEY COMPANY COLOMBIA S.A.,

Tax ID No. 800.236.937

Carrera 50 No. 17 -77 Bogotá D.C., Colombia

Phone +57 6107044

Email: LATAM.Privacidad@disney.com

Use of Information

If you are located in Colombia, or any of your affiliates or subsidiaries is domiciled in Colombia, we may use the information collected from you for the following purposes in addition to those described above in this Privacy Notice:

to link to potential or current customers;
to check the background of related persons (legal representatives, shareholders, associates, partners, officers, directors, employees, agents, subcontractors, delegates, etc.) on the KYC forms, or in supporting documents, on binding international lists for each of the jurisdictions (as applicable), on the list published by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC list) and on other public or private lists and databases (including those of third party suppliers) relating to persons allegedly linked to money laundering and terrorist financing activities;
to review, request information or documents, and generate reports (directly or through third parties) associated with controls and procedures in place for the management and mitigation of risks associated with AML/CFT;
compliance with SAGRILAFT-related standards, local standards, policies and manuals; and
to request updates to KYC forms and communications related to reports and findings associated with AML/CFT.

We may also share, transmit and transfer Personal Information within The Walt Disney Family of Companies and with third party providers of restrictive lists and due diligence for the prevention of AML/CFT for the purposes described in this Privacy Notice.

Your Rights

You have a number of rights under Colombian data protection law, including the right to access, update and rectify your Personal Information. These rights may be exercised against partial, inaccurate, incomplete, fractional or error-prone data, or Personal Information whose processing is expressly prohibited or has not been authorized, but please note that we will always seek your consent to treat your Personal Information. You may also request the deletion of your Personal Information when constitutional and legal principles, rights and warranties are not respected by us, and you may revoke the consent you have freely provided. You may also request proof of consent from us, except where applicable law does not expressly require consent to processing. You may freely (free of charge) access your Personal Information at least one (1) time every month or at any time when material changes are made to this Privacy Notice. You may also file complaints with the Superintendency of Industry and Commerce regarding violations of Colombia’s General Data Protection legal framework. Finally, you can also ask us or our data processors to inform you about the use of your personal data.

Procedures for Exercising Your Rights

Request to Access.

You, your successors, representatives and/or proxies, or the representatives of minors, may submit requests regarding what Personal Information is stored in our databases, what processing it is subject to, and what the purposes of the processing are. This procedure will be guided by the following rules:

Requests must be submitted in writing and by email. We will record the receipt and processing of the request.
The request will be reviewed to verify your identity. If the request is submitted by someone other than you (the data subject), and the individual is unable to provide evidence that they are acting legitimately on your behalf, the request will be rejected.
We are responsible for processing the request; therefore, we will provide you with a response within ten (10) business days of the date we receive the request.
In the event that a response to the request cannot be provided within ten (10) business days, we will inform you of the reasons why the request is still pending and provide you with the date on which the request will be addressed, which in any event shall not exceed five (5) business days following the expiration of the first term.
We will provide you with an email response.
The final response to all requests will take no more than fifteen (15) business days from the date we receive the initial request.

Submission of complaint(s) to update, modify or delete your Personal Information and/or withdraw consent:

You, your successors, representatives, and/or proxies, or representatives of minors, who believe that Personal Information contained in our databases need to be rectified, updated, or deleted, or who detect a breach of duties by The Walt Disney Family of Companies, may file a complaint.

This procedure will be guided by the following rules:

The claim must be submitted in writing and by email. We will record the receipt and procedure of the claim.
The claim will be reviewed to verify your identity. If the request is submitted by someone other than you (the data subject), and the individual is unable to provide evidence that they are acting legitimately on your behalf, the request will be rejected.
The claim must include the following information: (i) your name and identification; (ii) your contact information (physical address and/or electronic address and telephone number); (iii) the documents evidencing your identity or the corresponding representative documents in the event that you are a successor, representative and/or attorney-in-fact; (iv) a clear and accurate description of the personal information you seek to update, modify, delete or withdraw consent (v) a description of the events giving rise to the claim; (vi) all documentation you wish to use; and (vii) your signature and identification.
If the claim or documentation is incomplete, we will ask you, within five (5) business days of receipt of the claim, to remedy the faults. If you do not submit the required documentation and information within two (2) months of the date of the initial claim, we will understand that you have waived the claim.
Upon receipt of the claim with the complete documentation, a caption stating “claim in process” and the reason for the claim will be included in our database where the personal information is contained, within two (2) business days. This caption will remain in place until the claim is resolved.
We will provide a response to the claim no later than fifteen (15) business days from the day following the date of receipt. When the claim cannot be addressed within said period, you will be informed of the reasons for the delay and the date on which your claim will be addressed, which in any case will be no later than eight (8) business days after the date on which the initial claim is received.

Request to Delete.

You have the right at all times to submit a request to delete your Personal Information from our database, provided that:

You feel that your personal information is not being processed in accordance with the principles, duties and obligations set out in Law 1581 of 2012.
There is no legal duty or contractual obligation that obligates us to keep your Personal Information in its database.
As long as the time required to fulfill the purpose for which the personal information was collected has expired.

Withdrawal of consent.

You may always withdraw your consent to the processing of Personal Information, unless any legal provision prohibits it or there is a legal or contractual obligation that allows us to continue to process your personal information.

We will retain evidence of the inquiry, claim or request and of its response.

DEFINITIONS

“Anonymous Information” is information that does not directly identify, and cannot reasonably be used to directly or indirectly identify, an individual person.

The “Data Controller” is the subsidiary or affiliated entity of The Walt Disney Company that is responsible for the Personal Information collected and used within the scope of this policy from our sites and applications.

A “Data Processor” is a person or entity that processes Personal Information on behalf of a Data Controller (or Data Controllers) and that is permitted to perform data processing only as directed by the Data Controller(s).

“Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked (whether directly or indirectly) with a particular individual or household, such as the individual’s name, postal address, email address, and telephone number. When Anonymous Information is directly or indirectly associated with Personal Information, the resulting information is also treated as Personal Information.

“Sensitive Personal Information” means (i) Personal Information that reveals (a) an individual’s social security, driver’s license, state identification card, or passport number; (b) an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) an individual’s precise geolocation; (d) an individual’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of an individual’s mail, email, and text messages unless the business is the intended recipient of the communication; or (f) an individual’s genetic data; (ii) the processing of biometric information for the purpose of uniquely identifying an individual; or (iii) Personal Information collected and analyzed concerning an individual’s health, sex life or sexual orientation.

The “Walt Disney Family of Companies” refers to The Walt Disney Company and its subsidiary and affiliated entities, which offer their products and services under various brand names. These companies engage in a number of businesses, including theme parks and travel, motion pictures and television, publishing, consumer products and interactive services. The Walt Disney Company brands include, among others, the following: ABC Entertainment; ABC News; Adventures by Disney; Aulani, a Disney Resort & Spa; Bamtech Media; Bindass; Buena Vista Catalog Company (including Disney Movie Club); D23 | The Official Disney Fan Club; Disney Baby; Disney Channels & DisneyNOW; Disney Cruise Line; Disney Digital Network; Disney Family Movies; Disney Movie Insiders; Disney on Broadway; Disney on Ice and Disney Live!; Disney PhotoPass Service; Disney Rewards Visa Card; Disney Vacation Club; Disney+; Disneyland Paris; Disneyland Resort; DisneyLife; El Capitan Theatre; ESPN; ESPN CricInfo; ESPN Deportes; ESPN+; FiveThirtyEight; Freeform; FX Networks; Genx Entertainment Limited; Hollywood Records; Hulu; Hungama TV; Lucasfilm (Star Wars); Marvel; Marvel Shop; Marvel Digital Comics; Muppets; National Geographic; Pixar Animation Studios; Radio Disney; Read Riordan; shopDisney; The Undefeated; 30 for 30 Podcasts; United Home Entertainment Private Limited; UTV Software Communication Limited; Walt Disney Pictures; Walt Disney Studios Home Entertainment; Walt Disney World Resort.