1. How we obtain Personal Data and what we use it for

Personal Data we may hold and process includes any personal data or registration details provided to us via World Family Club membership application forms, customer-service emails sent to us, or information entered via online chat windows on the Disney World of English website. No sensitive personal data should be or is required to be submitted to us in order to register for a membership with us or use any of our services.

• Our apps and other services are occasionally marketed to children under the age of 13. However, we never use the Personal Data of any child without express permission from a parent or legal guardian.

• Your data are used by us in order to provide you with services such as answering customer-service inquiries and maintaining a record of your membership with us, and in accordance with our legitimate interests or those of a third party. Where we rely on our legitimate business interests or the legitimate interests of a third party to justify the purposes for using your Personal Data, our legitimate interests will usually be:

  1. pursuit of our commercial activities and objectives, or those of a third party (for example, analysing the effectiveness of our tools and services and improving these);

  2. carrying out direct marketing relating to other products or services offered by us subject to any preferences expressed to us;

  3. improvement and development of our business operations and service offering, or those of a third party;

  4. protection of our business or that of a third party (for example, ensuring IT network and information security);

  5. maintaining records relating to business activities, customer relationships and sales; and

  6. complying with legal and other requirements, record-keeping and reporting obligations, conducting audits, compliance with requests from government or other public authorities, responding to legal process such as subpoenas, summons or warrants, pursuing legal rights and remedies, defending litigation and managing any complaints or claims and conducting investigations.

• If you decline to provide your information to us or request it to be deleted, then there will be no effect on your ability to use our website or most of our app functions. However, refusal to provide Personal Data may prevent you from registering a World Family Club membership and may impact our ability to effectively address customer-service requests from you or provide you with customized offers.

2. Sharing of Personal Data

In connection with the purposes described above, we may need to share your Personal Data with third parties. These third parties may include external third party service providers, such as call centre providers, security professionals and other professional advisors, IT systems, marketing agents, support and hosting service providers, and other third party vendors and outsourced service providers and group companies that assist us in carrying out business activities relevant to our services.

3. Transfers of Personal Data

For the purposes set out above we may, from time to time, transfer Personal Data to service providers or other parties located in other countries.

• When making these transfers, we will take steps to ensure that your Personal Data are adequately protected and transferred in accordance with the requirements of data protection law.

• This may involve the use of data transfer agreements, for example, in the form recognised by data protection law as ensuring an adequate level of protection for Personal Data transfer.

• For further information about these transfers and to request details of the safeguards in place, please contact us using the details below.

4. Retention of Personal Data

We will keep Personal Data for as long as is necessary for the purposes for which we collect such Personal Data. Where we hold Personal Data to comply with a legal or regulatory obligation, we will keep the information for at least as long as required to comply with that obligation.

• Where we hold Personal Data in order to provide a service, we will keep the information for at least as long as we provide the product or service, and for a number of years thereafter, which may vary based on the requirements of a local jurisdiction, and will be retained for a longer period in the event of legal or prospective legal proceedings. Generally, data relating to our contractual relationships are retained for between 18 months and 5 years after termination of our contractual relationship.

• For further information about the period of time during which we retain your Personal Data, please contact us using the details below.

5. Your Personal Data Rights

The following is a summary of the data protection rights available to individuals in connection with their Personal Data. These rights may only apply in certain circumstances and can be subject to certain legal exemptions.

• You may request access to or a copy of your personal data;

• You may rectify inaccurate personal data held about you;

• You may request us to erase your personal data;

• You may restrict (or suspend) the processing or use of your personal data;

• You have the right to data portability of the personal data you have provided to us;

• You may object to the processing of your personal data;

• You may withdraw any consent, such as the consent given by filling out an information request form from us, that you provided us to collect and process your personal data;

• You may complain to the Data Protection Commission or other such regulatory authority of your jurisdiction in the event you have a complaint or believe your rights have been infringed (we request that you also bring these matters to our attention so that we may work with you to resolve the issue quickly).

If you wish to exercise your rights, please contact us using the details below.

6. Who to contact about your Personal Data

If you have any questions or concerns about the way your Personal Data are used by us, you can contact us by e-mail at: [email protected]

• This Privacy Policy was last updated on April 2, 2019. We may review this policy and make changes from time to time.

• We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business, legal requirements, and the manner in which we process Personal Data.