Disney Campaign Manager Privacy Policy

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Privacy Policy for Disney Campaign Manager

Last Updated: March 29, 2024

  1. Introduction
  2. Information We Collect
  3. Use of Information We Collect
  4. Sharing Information with Others
  5. Your Controls and Choices, Including Opt-Out Options
  6. Security and Account Access
  7. Children
  8. Applicable Law
  9. Changes to this Privacy Policy
  10. Questions/Contacting Us

1. Introduction

Disney Campaign Manager is a self-service platform for advertising on Hulu, and is operated by Hulu, LLC (“Hulu,” “we” or “us”). Hulu respects your privacy. This Privacy Policy explains the collection, use, and sharing of information from or about you in connection with your use of the Disney Campaign Manager and all associated business tools and services, including any beta versions, for advertising on Hulu where this Privacy Policy is posted (collectively, “Disney Campaign Manager Services”).

To learn more about Hulu’s collection, use, and sharing of information in connection with Hulu streaming services available on hulu.com, Hulu applications, and other places through which Hulu streaming services may be accessed, please visit our consumer privacy policy at https://privacy.thewaltdisneycompany.com/en/current-privacy-policy/ (“Consumer Privacy Policy”). This Privacy Policy does not apply where our Consumer Privacy Policy is posted or applies. Please also note that the Disney Campaign Manager Services may contain links to other sites owned or operated by other companies, including our advertisers, and Hulu does not notify you when you have chosen to click through to another website or property when using the Disney Campaign Manager Services. We recommend that you review the privacy policies of such other websites or properties.

By utilizing Disney Campaign Manager Services, you consent to the collection and use of information from or about you and the business entity you represent as explained in this Privacy Policy. If you do not consent to the collection and use of information from or about you in accordance with this Privacy Policy, then you may not use Disney Campaign Manager Services.

2. Information We Collect

Hulu may collect the following information from or about you, including personal information, from the following sources:

Information You Provide to Us. We collect information you provide to us. For instance, when you register to use the Disney Campaign Manager Service through your advertiser account, we may collect identifiers and personal information including your name, business name, business email address, business phone number, credit card or other payment method information, business address, ZIP code, and other information. We collect details about the business that you represent, including EIN, business registration details, and other information. In addition, Hulu may collect information you provide to us when you upload content (including ad content or to verify your business) to Disney Campaign Manager Services, respond to surveys, contact Hulu through customer service or communicate with us by other means, or participate in promotions or events. We may also collect information you provide when you make changes to your account profile or update your Disney Campaign Manager preferences.

Usage, Technical and Log Data. When you use the Disney Campaign Manager Services, we may collect information from and about the browser or device you’re using and information about your internet or other electronic network activity, including through analytics tools and the technologies described below (“Data Collected Through Cookies and Similar Technologies”). This information may include your IP address, device type, browser and software characteristics (such as type and operating system), geolocation data (which may include precise location data), referral URLs, network state, device identifiers or other unique identifiers such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and identifiers associated with browser cookies (see our description of “Cookies and Local Storage” below), and carrier information. We also collect information about your activity on the Disney Campaign Manager Services including information about the campaigns you create, the materials and resources with which you engage (e.g., knowledge articles and webinars), and your targeted audience.

Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. These technologies are discussed below.

  • Cookies and Local Storage. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the Disney Campaign Manager Services, to monitor aggregate usage by our users and web traffic routing on the Disney Campaign Manager Services, and to customize personalized advertising. These uses allow us to improve the Disney Campaign Manager Services. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences. We may collect information through other kinds of local storage (also referred to as “Flash cookies”) and HTML5 local storage. Because these technologies are similar to browser cookies, they are sometimes called “browser cookies,” even though they may be stored in different parts of your computer.

    You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. For information about disabling cookies or deleting information contained in Flash cookies, please click here. Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the Disney Campaign Manager Services, including not being able to store your preferences or login information.

  • Web Beacons, Pixels and mobile SDKs. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, the time and date on which you viewed or used the Disney Campaign Manager Services, the IP address of your computer, and the URL of the web page from which the Disney Campaign Manager Services were viewed. We may also use or work with third parties including our business partners and service providers who use mobile Software Development Kits (“SDKs”) to collect information, such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and information related to how mobile devices interact with the Disney Campaign Manager Services.

The use of these various technologies in connection with advertising on the Disney Campaign Manager Services is explained further below. To learn about opting out of interest-based or online behavioral advertising, please see the information we have provided in Section 5 (“Your Controls and Choices, Including Opt-Out Options”) below.

Information from Partners and Other Sources.

We may collect information about you from other sources, including service providers (e.g., data licensors, research and analytics companies, and payment processors), public databases, our marketing partners, and advertisers. This may include information (whether identifiable, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and advertisements viewed).

We may use the information we collect from or about you to better understand your preferences and behaviors, including to customize personalized advertising for you. We may combine the information we collect from or about you and use it in the manner described in this Privacy Policy or as otherwise permitted by law.

3. Use of Information We Collect

Use in General. We use the information we collect from or about you in order to help deliver a first-class user experience, including for the following purposes:

  • providing the Disney Campaign Manager Services, including customer support;
  • contacting and communicating with you, including for information on your account, transactions with us, or feedback about features on our sites and applications or changes to our policies, promotions, updates, and notifications;
  • customizing the Disney Campaign Manager Services and evaluating how well the Disney Campaign Manager Services perform;
  • managing our suppliers, independent contractors, service providers and others throughout the supply chain;
  • administering surveys, sweepstakes, contests, and other promotional activities or events;
  • customizing recommendations;
  • operating and optimizing the Disney Campaign Manager Services, such as by conducting analytics and research;
  • compiling aggregate data for internal and external business purposes;
  • detecting security incidents, preventing potentially fraudulent, illegal or harmful activities and otherwise enforcing the Disney Campaign Manager Terms and other policies;
  • protecting your and our rights and complying with legal obligations;
  • other uses in accordance with our Disney Campaign Manager Terms; and
  • any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.

Use of Payment Information. We use payment information, such as credit card numbers and billing ZIP code, and commercial information, such as the Hulu campaigns you create and purchase, to help provide the Disney Campaign Manager Services. For example, we use payment information to process payments (we use a third-party payment processor to do this), to retrieve account information for advertisers, to determine whether an advertiser is eligible for promotions, and to detect abuse of the Disney Campaign Manager Services.

Use of Aggregate or De-Identified Information. In addition to the individual data use described in this Privacy Policy, we may aggregate information about you and other advertisers together or otherwise “de-identify” the information about you (which means that the information does not directly or indirectly identify you). We may use information in these forms for any legitimate business purpose, including for research and analysis, administration of the Disney Campaign Manager Services, advertising (e.g., improving our targeting efforts), and promotional purposes.

Retention of Data. We retain your information as long as it is necessary for us to provide the Disney Campaign Manager Services and to fulfill our contractual obligations and rights. If we retain additional information, we retain it only for so long as we have a legitimate business purpose in keeping such data.

4. Sharing Information with Others

We may share the information collected from or about you with the following:

  • Service Providers. We may share your information with third party service providers that provide business, professional, or technical support functions for us, help us operate the Disney Campaign Manager Services, or administer activities on our behalf. The categories of information that we share with service providers will vary depending on the types of services they provide. For example, we share payment information with our third-party payment processor to assist us in our billing efforts, email addresses with our marketing service providers to assist with our email campaigns, and IP address, hashed emails, and advertising identifiers with service providers to assist in our advertising and marketing efforts.
  • Partners and Affiliates. We may share your information with select partners, affiliates, and other third parties that we believe may have offers of interest to you.
  • Third Parties When Required By Law or When Necessary to Protect Your or Our Rights. In some instances, we may disclose information from or about you without providing you a choice. For example, we may disclose your information in the following ways: to protect the legal rights of Hulu and our affiliates or partners; to protect the safety and security of users of the Disney Campaign Manager Services or third parties; to enforce our Disney Campaign Manager Terms; to protect against fraud; and to comply with or respond to the law or legal process or a request for cooperation by a government entity, whether or not legally required.
  • Third Parties in Connection with Certain Transactions. If we sell all or part of our business, make a transfer of assets, or otherwise might be involved in a change of control transaction, or in the event of bankruptcy, we may transfer information from or about you to one or more third parties as part of the transaction, including the due diligence process.
  • Parties with Your Consent or When You Otherwise Choose to Share. We may also share information from or about you with any party when we have your consent or when you otherwise choose to share such information.

5. Your Controls and Choices, Including Opt-Out Options

You have the following controls and choices regarding how we and third parties use certain information collected from or about you.

Opt-Out Options for Third-Party Online Behavioral or Interest-Based Advertising.

  • Advertising that is based on information collected from or about you across websites, applications and other platforms over time is known as online behavioral or interest-based advertising. Some of the third parties (e.g., ad networks and partners; data exchanges; marketing analytics, digital advertising and marketing service providers) that collect information from or about you on the Disney Campaign Manager Services in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and/or may be members of the Network Advertising Initiative (“NAI”). Hulu is committed to complying with the DAA Self-Regulatory Principles for Online Behavioral Advertising and the DAA Application of Self-Regulatory Principles for the Mobile Environment.
  • To learn more and to make choices about the use of information from or about you for online behavioral or interest-based advertising on websites (desktop and mobile browsers), please visit the DAA and the NAI. You may also use the opt-out mechanism in the “About Ads” link at the bottom of the Disney Campaign Manager site. You can also exercise controls through the settings available to you through your device(s), such as re-setting your device’s advertising identifier, selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices). Please note that your opt-out choices will only apply to the specific browser or device from which you opt out.
  • There is currently no consensus among industry participants as to what “Do Not Track” means and how to respond to “Do Not Track” browser signals. As such, we do not respond to such signals. Instead, to opt-out of website-based third-party interest-based or online behavioral advertising, please exercise one of the choices listed above.

6. Security and Account Access

The security of your information is important to us. We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to those Hulu employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission.

Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur and we cannot guarantee the security of any information from or about you 100% of the time. Please refer to the U.S. Federal Trade Commission’s website for information on how to protect yourself from identity theft.

7. Children

Disney Campaign Manager Services are only for users over the age of 18 acting on behalf of a business entity and are not directed at persons under the age of 18. If we become aware that we have unknowingly collected personal data about a child under 18 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 18 year of age who has provided us with personal data, you may contact us to request it to be deleted.

8. Applicable Law

Hulu is headquartered in the U.S. and the Disney Campaign Manager Services are intended for users in the U.S. By utilizing Disney Campaign Manager Services, you consent to the collection, storage, and processing of information under U.S. laws.

9. Changes to this Privacy Policy

From time to time, we may revise this Privacy Policy to reflect changes in the law or the Disney Campaign Manager Services or for other reasons. Therefore, it is important to check the date posted at the top of the Privacy Policy each time you visit the Disney Campaign Manager site or use any of the Disney Campaign Manager Services to ensure you are familiar with our most updated policies and practices. If we make any material change to this Privacy Policy, we will provide notice to you in accordance with applicable law. Notice may be made by posting a notice on the Disney Campaign Manager site, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your advertiser account information, including email address, updated.

10. Questions/Contacting Us

At Hulu, we expect that our first-class customer support team will be able to resolve most issues you may have using the Disney Campaign Manager Services. You can find answers to frequently asked questions or contact our customer support team by going to our FAQ page. In addition, if you have any questions regarding this Privacy Policy, you may email us at [email protected] or contact us by mail addressed to:

Attention: Legal Department
Hulu, LLC
2500 Broadway, 2nd Floor
Santa Monica, CA 90404

Thank you for taking the time to read this Privacy Policy. We hope you enjoy the Disney Campaign Manager Services!