ATTACHMENT C-1
ON-LINE PRIVACY POLICY
Updated: September 12, 2008
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.
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Q2 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.
Q3 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.
Q4 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.
Q5 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.
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Q6 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.
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Q7 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.
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Q8 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.
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Q9 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 also will be shared with The Walt Disney Company (Canada) Limited so that it can send you promotional materials. To request a copy of The Walt Disney Company (Canada) Limited Privacy Policy or if you do not want to receive future promotional communications from The Walt Disney Company (Canada) Limited regarding Walt Disney World, Disneyland or Disney Cruise Line products, services or special offers, please call 1-800-499-6583.
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