Data Collection and Use Policy

Data Policy

The following are policies surrounding advertising data and its use collected from any Disney Property. “Disney Property” means any website, mobile application or other online service that is owned, licensed, affiliated, branded, controlled, or managed by Disney, or a property on which Disney has a contractual right to run campaigns. “Disney” means the a specific entity(ies) of the Walt Disney Company, by way of example only, ABC Network, ABC Owned Television Stations, ESPN, Disney Channels Worldwide, Marvel, Freeform, Disney Digital Network, Hulu, etc.

• Ads may be tagged solely for the purpose of collecting data geared toward measuring performance of a campaign (e.g., ROI, attribution, impact, verification), in each case, as approved by Disney. No browser-based cookies, Flash cookies, web beacons, pixels, tags or any other technology designed to track end-users’ activity for any purpose (including, without limitation, to target or retarget ads) on any Disney-branded, -owned, -licensed, -affiliated or –controlled website, application, or other online product or service distributed via any means or media may be included in ads without Disney’s prior written consent.
• Any vendor utilized by an agency or client, if it seeks to place pixels, tags or other data collection on ad tags, or if it seeks to deliver creative to Disney’s pages, utilizes technology to provide creatives, or seeks to use its own data, through aggregation of Disney data, to develop models or attributional results and performance related reports, must be approved by Disney and sign a Vendor Agreement. Disney must pre-approve all third party vendors used by advertisers and agencies and such vendors may be required to acknowledge and agree to comply with Disney’s policies. Disney reserves the right to disapprove use of any advertiser’s or agency’s third party vendor.
• Any Data Management Platform (DMP) utilized must have a specific and limited purpose, which Disney must review and approve, and the platform itself must be an approved vendor. Each client utilizing the DMP must sign an Advertiser Agreement to adhere to Disney’s guidelines on data usage.
• Disney must be notified of all data being collected in connection with a campaign by an advertiser, agency and/or third party vendors acting on their behalf for the purpose of verifying that such data collection activity is acceptable to Disney. All data collected in connection with a campaign (including, without limitation, personally identifiable information) must be approved by Disney in writing prior to the campaign start date.
• Any campaign intended to capture information for the purpose of serving ads to, or otherwise targeting or actively engaging with, Disney users outside of Disney platforms, is prohibited (e.g., no database, network or exchange may be built and/or exploited as “Disney users”).
• Data collected may not be sold or otherwise transferred to any third party for any use, outside of what has been explicitly and mutually agreed to in writing prior to the campaign, and must be destroyed within thirteen (13) months from the date of collection.
• Data collected must be made available for review by Disney at Disney’s request.
• Advertisers, agencies and third party vendors acting on their behalf must comply with the Behavioral Advertising Self-Regulatory Principles, which may be found at the following URL: https://www.iab.com/news/self-regulatory-principles-for-online-behavioral-advertising/. If applicable, all vendors must be MRC certified.
• With respect to the delivery of ads from a third party service or vendor, the delivery may not be blocked or otherwise limited for any reason relating to impression delivery without the approval of Disney. Clients required to meet federal guidelines (such as Pharmaceuticals) may be allowed to utilize third party blocking, in some exceptions.
• The onboarding of data from client’s 3rd or 1st party data sources into the Disney DMP must have Disney approval. Disney will supply an Onboarding Agreement, which must be signed by the Agency or Client (whoever owns the data) which assures the quality and security of the data to be utilized.
• In the event of a client request for Disney tagging a client page to track attribution or enable targeting on Disney, Disney will provide an agreement outlining the terms of the data to be collected and how it may be used.