ATTACHMENT C-1
ON-LINE PRIVACY POLICY
Updated: February 24, 2009
We at Disney Photo Imaging, LLC are dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. This Privacy Policy is designed to answer your questions regarding our privacy policies and principles with respect to personally identifiable information collected on the site where this Privacy Policy is posted.
Kids' Privacy Policy:
We take measures to prevent kids who are under the age of 13 from supplying personally identifiable information on the site where this Privacy Policy is posted and we do not knowingly collect personally identifiable information from kids who are under the age of 13.
Q1 - What information does this Privacy Policy cover?
A1 - Except as specifically described below in A2 and A6, this Privacy Policy applies only to personally identifiable information collected on the Web site where this Privacy Policy is posted and does not apply to any other information collected by Disney Photo Imaging, LLC through any other means. This Privacy Policy applies to use and sharing of personally identifiable information collected on and after the date that this Privacy Policy is posted.
As used in this Privacy Policy:
"Disney’s Parks and Resorts" includes all of the theme parks, resort hotels, timeshare accommodations, cruise ships and other similar attractions and accommodations operated now or in the future by the Walt Disney Family of Companies, including, for example, the Walt Disney World® Resort, the Disneyland® Resort, the Disney Cruise Line® Services and the Disney Vacation Club.
"The Walt Disney Family of Companies" includes The Walt Disney Company and all of its subsidiary and affiliated entities.
"The Walt Disney Family of Companies" does not include Disney Photo Imaging, LLC.
Disney Photo Imaging, LLC is referred to in this Privacy Policy as "we," "us," "our," and "ourselves."
In keeping with the traditions of The Walt Disney Company, we refer to customers of Disney Photo Imaging, LLC and The Walt Disney Family of Companies as "guests." When this Privacy Policy uses the term "personally identifiable information," we mean information that identifies a particular individual, such as the individual’s name, postal address, email address, and telephone number. When other information, such as, for example, consumer product preferences, or number of children, is directly associated with personally identifiable information, this other information also becomes personally identifiable information for purposes of this Privacy Policy. Personally identifiable information is sometimes referred to in this Privacy Policy as "personal information." Finally, the terms of this Privacy Policy are subject to all applicable laws.
Back to TopQ2 - What types of personally identifiable information do we collect about our guests?
A2 - We collect several types of personally identifiable information about our guests.
Information You Provide to Us
Much of the personally identifiable information we receive comes directly from guests who are interested in obtaining products and services from us. Typically, this information includes the guest’s first and last name, postal address, and email address. We may also collect other types of information such as gender, age, number of children, and personal interests, which we may associate with personally identifiable information. If you purchase products or services, we’ll note, for example, credit card information, telephone number, the type of services or products ordered or purchased, and the date of the order or purchase. We may collect personal information when you register on, log on, or visit our site, including when you participate in activities on our site, such as sweepstakes, contests, games and promotional offers.
Information Collected Through Technology
We collect information through technology to make our site more interesting and useful to you. For instance, when you come to one of our sites, we may collect your IP address. An IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet service provider), your company, or your university. Standing alone, your IP address is not personally identifiable. At times, we may also use IP addresses to collect information regarding the frequency with which our guests visit various parts of our site. We may combine this information with personally identifiable information.
Our site may also use cookies. Cookies are pieces of information that a site sends to your computer while you are viewing the site. We and other companies use cookies for a variety of purposes. For instance, when you return to our site after logging in, cookies may provide information to the site so that the site will remember who you are. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Netscape Navigator or Internet Explorer) settings. 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 may not have access to many features that make your Web experience smoother, like the features mentioned above, and some of our services may not function properly.
Our site may use a variety of technical methods for tracking purposes, including Web beacons. Web beacons are small pieces of data that are embedded in images on the pages of a site. We may also use these technical methods to analyze the traffic patterns on our site, such as the frequency with which our users visit various parts of our site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML emails that we send our guests to determine whether our guests have opened those emails and/or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is personally identifiable.
Advertisements may be managed and placed on our site by third parties. These companies are called "network advertisers." Network advertisers who place advertisements on our site may also use cookies and Web beacons to collect non-personally identifiable information when you click on or move your cursor over one of their banner advertisements. You may not realize this information is being collected. In some cases, we may have access to information from Web beacons and cookies used by network advertisers on our site and this information may permit us to identify other sites that you have visited that are also associated with the network advertiser. Finally, once you've clicked on an advertisement and have left our site, our Privacy Policy no longer applies and you must read the privacy policy of the advertiser to see how your personal information will be handled on their site.
Information That We Collect from Others
We may supplement personally identifiable information that we have collected directly from our guests with other information that we obtain from third parties and various members of The Walt Disney Family of Companies. In addition, we may obtain information about individuals who are not yet users of our site or guests of The Walt Disney Family of Companies. In addition, when we associate information that we obtain from third parties or members of The Walt Disney Family of Companies with personally identifiable information that we have collected under this Privacy Policy, we will treat the acquired information like the information that we collected ourselves and, except as permitted by this Privacy Policy, the information will not be shared with third parties.
Back to TopQ3 - How is your personally identifiable information used and shared?
A3 - As described in detail below, Disney Photo Imaging, LLC may use your personally identifiable information in many ways, including sending you promotional materials, and sharing your information with members of The Walt Disney Family of Companies so that they can send you promotional materials. (By "promotional materials," we mean communications that directly promote the use of our site, or the purchase of products or services.) As outlined below in A4, you may "opt-out" of certain uses of your personal information.
Disney Photo Imaging, LLC
Personally identifiable information collected under this Privacy Policy is used by Disney Photo Imaging, LLC for many purposes. For example, Disney Photo Imaging, LLC may use your personal information to send you promotional materials about goods and services (including special offers and promotions) either offered by Disney Photo Imaging, LLC or Disney’s Parks and Resorts around the world. These promotional materials may be sent to you by postal mail, email or other means. You may opt out of receiving these communications as provided in A4 below. Please keep in mind, however, that when you purchase or request products or services, promotional materials may accompany delivery of that product or service. We refer to sending you promotional materials in these circumstances as "Fulfillment Uses" of your personal information. Because these promotional materials accompany products or services that you have requested, your opt-outs under A4 below will not apply to any of these Fulfillment Uses.
Disney Photo Imaging, LLC may also use your personal information for many purposes other than sending you promotional materials. (We refer to all of these types of uses of your personal information that do not involve the sending of promotional materials as "Operational Uses.") For example, we may use your information to complete transactions requested by you (such as your purchase of a product or service offered on our site), or to send you administrative communications either about an account that you may maintain with us or about features of our products, including any future changes to this Privacy Policy. Because these uses of your personal information do not involve sending you promotional materials, your opt-outs under A4 below will not apply to any of these Operational Uses.
Finally, Disney Photo Imaging, LLC may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under this Privacy Policy upon the right of Disney Photo Imaging, LLC to aggregate or de-personalize your personal information, and Disney Photo Imaging, LLC may use and/or share with The Walt Disney Family of Companies or third parties the resulting non-personally identifiable information in any way.
Disney’s Parks and Resorts Around The World
Subject to your opt-out choice (see A4 below), Disney Photo Imaging, LLC may share your personal information with members of The Walt Disney Family of Companies so that they can send you promotional materials about Disney’s Parks and Resorts around the world (including special offers and promotions). (We call this type of sharing "promotional sharing" or sharing for "promotional purposes.") If Disney Photo Imaging, LLC shares your personal information with The Walt Disney Family of Companies as described in this Section, your personal information will become permanently subject to the information use and sharing practices of the member of The Walt Disney Family of Companies that receives your personal information, and any subsequent opt-out election that you make will not affect that entity’s ability to send you promotional materials or share your information.
Companies That Facilitate Communications and Transactions with You
Sometimes Disney Photo Imaging, LLC works with other companies to provide products or services to you. For example, a third party provides technical services related to your Disney PhotoPass pictures, including engaging in transactions for your purchase of copies of your pictures. In addition, members of the Walt Disney Family of Companies may assist Disney Photo Imaging, LLC to deliver products and services to you. In these instances, there is a need to share your information with these other companies. Sometimes Disney Photo Imaging, LLC also works with other companies who help either gather your information or communicate with you. Your opt-out choice under A4 below will not apply to sharing by Disney Photo Imaging, LLC of your personal information with any of these companies. Nonetheless, except as separately permitted by other provisions of this Privacy Policy, these companies are allowed to gather, receive, and use your information only for the purposes described in this paragraph or as required by law.
Sale of Business
We may sell all or part of our business and your personally identifiable information may be transferred as a part of the sale. In the event that we sell all or part of our business, we will include provisions in the selling contract requiring the purchaser to treat your personally identifiable information in the same manner required by this Privacy Policy (including any amendments to this Privacy Policy). In light of this protection, your opt-out choice under A4 will not affect our right to transfer your information to a purchaser in these circumstances.
Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Web Site, Disney Photo Imaging, LLC and Others
Regardless of any opt-out choice that you make under A4, Disney Photo Imaging, LLC will disclose personal information when it believes in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our Terms and Conditions; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our site, including the safety and security of property that belongs to Disney Photo Imaging, LLC or other parties.
Back to TopQ4 - What choices do you have about the collection, use, and sharing of your personally identifiable information?
A4 - When you register on our site, you will have the opportunity to choose not to receive promotional materials about Disney Photo Imaging, LLC and Disney’s Parks and Resorts. You may change your initial choice by updating your account information in the “My Account” section on The site. Please keep in mind that any choice to not receive communications about Disney Photo Imaging, LLC and Disney’s Parks and Resorts will not apply in situations where (a) you either have made, simultaneously make, or later make a specific request for information about Disney Photo Imaging, LLC or Disney’s Parks and Resorts, (b) Disney Photo Imaging, LLC uses your personal information for either "Operational Uses" or "Fulfillment Uses" (as described above in A3), or (c) Disney Photo Imaging, LLC shares your personal information under the provisions of A3 above with respect to "Companies That Facilitate Communications and Transactions With You," "Sale of Business," or "Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Web Site, Disney Photo Imaging, LLC and Others."
Finally, if you do not exercise your opt-out choices upon registration or initial log-in at our site, it may take up to ninety (90) days for your opt-out choice to be fully effective. Our systems require time to update, and promotional mailings using personal information that you provided before your opt-out may already be in process. Thus, you might continue to receive promotional materials about Disney Photo Imaging, LLC and Disney’s Parks and Resorts based upon the personal information you have provided under this Privacy Policy for up to ninety (90) days. In addition, the personal information that you have provided under this Privacy Policy may continue to be shared with members of The Walt Disney Family of Companies for up to thirty (30) days.
Back to TopQ5 - What kinds of security measures do we take to safeguard your personally identifiable information?
A5 - The security and confidentiality of your information is extremely important to us. We have implemented technical, administrative, and physical security measures to protect guest information from unauthorized access and improper use. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.
Back to TopQ6 - How can you update your contact information and opt out choices?
A6 - You can access and update the contact information you gave us during registration (that is, your postal address, email address, or any other information that would directly enable us to contact you), or modify your opt-out choice regarding receiving promotional materials, by going to the “My Account section on the site and making any changes desired and clicking “update”. We also may provide you an opportunity to update your contact information and/or modify your opt-out choice by sending you an email or other communication that invites your response. Finally you may unsubscribe from certain marketing email communications by clicking on unsubscribe links in those emails.
Back to TopQ7 - How can you ask questions, or send us comments, about this Privacy Policy?
A7 - If you have questions or wish to send us comments about this Privacy Policy, please send an email with your questions or comments to wdw.guest.communications@Disney.com or write us:
Disney Photo Imaging, LLC
PO Box 10,000
Lake Buena Vista FL 32830
Please be assured that any personal information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you so request.
Back to TopQ8 - How will you know if we amend this Privacy Policy?
A8 - We may amend this Privacy Policy at any time. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending you an email at the last email address that you provided us, and/or by prominently posting notice of the changes on the site covered by this Privacy Policy. Any material changes to this Privacy Policy will be effective upon the earlier of ten (10) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of notice of the changes on the site covered by this Privacy Policy. Please note that, at all times, you are responsible for updating your personal information to provide us your current email address. In the event that the last email address that you have provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of personal information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your information, you must so notify us prior to the effective date of the changes. In the event that you do so notify us, we reserve the right to delete your registration or other personal information and to cease offering you services that require our use of that registration or other personal information.
Back to TopQ9 - How will the personal information of residents of Canada be used?
A9 - In addition to being shared with domestic U.S. members of the Walt Disney Family of Companies, your information may be shared with The Walt Disney Company (“TWDC”) (Canada) Ltd. To request a copy of the TWDC (Canada) Ltd. Privacy Policy or if you do not want to receive future promotional communications from the TWDC (Canada) Ltd. regarding products and services of The Walt Disney Family of Companies, please call 800.499.6583.
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