California Legal professional Basic Rob Bonta in the present day introduced a settlement with The Walt Disney Firm resolving allegations that the leisure large violated the California Shopper Privateness Act by failing to completely implement shoppers’ requests to opt-out of knowledge sale and sharing throughout units and streaming providers. Beneath the settlement, which requires courtroom approval, Disney should pay $2.75 million in civil penalties and implement complete adjustments to how the corporate processes privateness requests throughout its streaming platforms.

The enforcement motion marks the fifth main CCPA settlement secured by Bonta’s workplace, following a $1.55 million agreement with Healthline Media LLC in July 2025 and a $1.4 million settlement with mobile gaming company Jam Cityin November 2025. The escalating penalty quantities sign intensifying state enforcement efforts towards firms whose opt-out mechanisms fail to satisfy statutory necessities.

In accordance with courtroom paperwork filed in Los Angeles Superior Courtroom, Disney operated two distinct opt-out strategies that every didn’t cease information sharing comprehensively. When shoppers used opt-out toggles embedded in Disney’s web sites and apps, the corporate utilized the request solely to the particular streaming service the person was watching, and sometimes solely to the particular system. When shoppers used Disney’s webform, the corporate stopped sharing private information by way of its personal promoting platform however continued promoting and sharing shopper information with particular third-party promoting know-how firms whose code Disney embedded in its web sites and apps.

Disney additionally failed to supply in-app opt-out strategies in lots of linked TV streaming apps, as an alternative directing shoppers to its webform. This method successfully left shoppers with no method to cease Disney’s promoting and sharing from these apps, in keeping with the grievance.

The settlement requires Disney to implement consumer-friendly, easy-to-execute opt-out processes permitting shoppers to opt-out with minimal steps throughout all Disney streaming providers. For logged-in shoppers, Disney should effectuate opt-out selections throughout all Disney streaming providers related to the buyer’s Disney account. The corporate should present clear and conspicuous opt-out hyperlinks inside all Disney streaming providers and guarantee these hyperlinks both instantly effectuate the buyer’s selection or direct the buyer to a discover of proper to opt-out containing an easy-to-use opt-out methodology.

Technical implementation failures uncovered

The enforcement motion reveals vital gaps between Disney’s said privateness practices and precise technical implementation. When a person requested to opt-out through an opt-out toggle in Disney’s web sites and apps, Disney solely utilized the request to the particular streaming service the person was watching, and sometimes solely the particular system the buyer was utilizing. This meant that in most situations, utilizing the toggle wouldn’t cease promoting or sharing from different units or providers linked to the buyer’s account.

For shoppers who opted out utilizing Disney’s webform, Disney solely stopped the sharing of private information by way of the corporate’s personal promoting platform and choices. Nonetheless, Disney continued to promote and share shopper information with particular third-party promoting know-how firms whose code Disney embedded in its web sites and apps.

The technical failures affected Disney’s streaming providers together with Disney+, Hulu, and ESPN+. These platforms function video providers that Disney gives and operates for shoppers to stream reside and on-demand content material over the web through web sites and functions for cellular and linked units.

Complete compliance necessities

The settlement imposes detailed technical necessities on Disney’s opt-out mechanisms. The corporate should adjust to CCPA provisions associated to required notices and shoppers’ proper to opt-out of promoting or sharing private data, together with Civil Code sections 1798.100, 1798.120, 1798.130, and 1798.135, together with implementing rules.

Disney should present clear and conspicuous discover to shoppers that the corporate conducts cross-context behavioral promoting utilizing private data obtained from third events. Such discover should present shoppers a significant understanding of the data being collected, the classes of sources from which the non-public data is collected, and direct shoppers to Disney’s discover of proper to opt-out of sale and sharing.

When a logged-in shopper opts out, together with by way of use of an opt-out choice sign, Disney should effectuate the buyer’s opt-out selection throughout all Disney streaming providers that Disney associates with the buyer’s Disney account. When a shopper just isn’t logged-in or doesn’t have a Disney account and that shopper opts out, Disney should inform the buyer that it might be essential to log-in to their Disney account or direct the buyer to supply the minimal quantity of private data essential to completely effectuate the buyer’s opt-out selection.

For shoppers who would not have a Disney account, select to not log-in to their account, or who don’t present the mandatory extra data, Disney should deal with the buyer’s opt-out selection as a request to opt-out of sale or sharing for that browser, software, or system and any shopper profile that Disney associates with that browser, software or system, together with pseudonymous profiles that Disney maintains in reference to promoting, sharing, or cross-context behavioral promoting.

The discover of proper to opt-out have to be formatted and designed to suit and scale to the net browser, software, or system the place it’s offered. The discover shall not require a shopper to unnecessarily search or scroll by way of textual content to effectuate Disney’s opt-out or use hard-to-find-links, unlabeled carets, arrows, or different hidden menu icons that add pointless steps and could also be unclear.

Broader business context

The Disney settlement arrives as Disney has been expanding its advertising technology capabilities throughout streaming platforms. In April 2025, Disney introduced vital developments in its promoting know-how, increasing biddable advert capabilities throughout its streaming platforms and integrating new programs to handle rising advertiser calls for within the reside content material house.

Disney’s promoting infrastructure consists of the Disney Actual-Time Advert Trade (DRAX), which the company has connected directly to major demand-side platforms together with Google’s Show & Video 360 and The Commerce Desk. These technical integrations, introduced in March 2024, considerably simplified how advertisers entry premium stock throughout Disney’s streaming platforms.

The settlement necessities handle basic challenges in how streaming platforms implement privateness controls throughout fragmented technical environments. Connected TV advertising continues experiencing rapid expansion, with business projections indicating CTV advert spending reaching $33.35 billion in 2025. The technical complexity of implementing privateness controls throughout sensible TVs, streaming units, gaming consoles, computer systems, cellular units, and tablets creates implementation challenges for platforms gathering and sharing shopper information for promoting functions.

California’s privateness enforcement demonstrates sustained dedication to making sure opt-out mechanisms perform as meant. The state has emphasised International Privateness Management as an automatic browser-based mechanism permitting shoppers to sign opt-out preferences with out making individualized requests on each web site. Disney’s settlement necessities embody particular provisions for processing opt-out choice indicators constantly with relevant CCPA obligations.

Settlement particulars and timeline

Disney should present compliance updates to the California Legal professional Basic’s workplace each 60 days till all Disney providers adjust to the opt-out necessities. Inside 180 days of the efficient date, and for a interval of three years thereafter, Disney should implement and preserve a program to evaluate and monitor whether or not the corporate is successfully offering strategies of opting out of promoting and sharing which can be consumer-friendly, simple to execute, require minimal steps, and which absolutely implement a shopper’s opt-out selection account-wide on every net property, software, and system used to entry Disney providers.

The corporate should doc and share the outcomes of this overview with the California Legal professional Basic in an annual report for 3 years from the efficient date. All experiences, critiques, and sharing of data pursuant to the judgment shall be handled as confidential and as exempt from disclosure underneath related public information legal guidelines.

Disney should adjust to a shopper’s opt-out selection as required by CCPA, together with notifying all third events to whom Disney has bought or shared a shopper’s private data after the buyer submits the request to opt-out and earlier than Disney complies with that request. Disney should direct these third events to adjust to the buyer’s request and ahead the request to some other individual to whom the third celebration has made the non-public data accessible throughout that point interval.

With respect to private data that Disney makes accessible to a 3rd celebration, Disney should take cheap and acceptable steps to make sure that such third events use such private data in a way in keeping with Disney’s obligations underneath the CCPA.

The settlement prohibits Disney from promoting or sharing the non-public data of shoppers that it has precise data are youngsters underneath 13 or minors aged 13 to fifteen except the minor or guardian, within the case of a kid, has affirmatively licensed such promoting or sharing, as set forth in Civil Code sections 1798.120(c), 1798.135(c)(5), and implementing rules.

Enforcement sample emerges

Legal professional Basic Bonta’s workplace has demonstrated sustained deal with firms that create friction for shoppers exercising privateness rights. The Healthline settlement in July 2025 revealed that even after customers activated a “triple opt-out” by way of cookie banners, privateness hyperlinks, and International Privateness Management, investigators noticed 118 cookies from promoting firms nonetheless being positioned, with monitoring persevering with to ship information transmissions to dozens of promoting companies.

The Jam Metropolis settlement in November 2025 discovered the cellular gaming firm failed to supply CCPA-compliant opt-out mechanisms in any of its 21 cellular functions regardless of gathering and sharing shopper private data virtually completely by way of these cellular platforms. The investigation revealed the corporate collected and shared shopper private data practically completely by way of cellular video games, creating obligations to implement in-app opt-out performance moderately than relying solely on website-based mechanisms that cellular app customers not often encounter.

Earlier CCPA settlements embody Sephora for $1.2 million in 2022, DoorDash for $375,000 in 2024, and Tilting Level Media for $500,000 in 2024. The escalating penalty quantities – from $375,000 to $1.4 million to $1.55 million and now $2.75 million – sign intensifying enforcement scrutiny of privateness compliance failures.

The California Division of Justice has performed investigative sweeps focusing on firms that seem to violate CCPA. In March 2025, the division despatched letters to promoting networks, cellular app suppliers, and information brokers showing to violate the statute. Related sweeps addressed streaming apps and units together with worker data practices.

Advertising and marketing business implications

The settlement establishes clear expectations that opt-out obligations lengthen absolutely to streaming providers no matter technical structure or enterprise mannequin selections. Corporations gathering and sharing shopper information for promoting functions throughout a number of units and platforms should implement opt-out mechanisms that perform comprehensively moderately than in device-specific or platform-specific silos.

For streaming platforms working subtle promoting know-how infrastructure, the enforcement motion demonstrates that technical complexity can not excuse incomplete implementation of privateness rights. Disney’s integration of programmatic promoting capabilities, dynamic advert insertion know-how, and real-time bidding programs created corresponding obligations to make sure privateness controls functioned throughout this technical ecosystem.

The requirement to inform third events of shopper opt-out requests and direct these third events to conform creates accountability all through the promoting provide chain. Disney should notify all third events to whom it has bought or shared a shopper’s private data after the buyer submits the request to opt-out and earlier than Disney complies with that request. This obligation extends the attain of shopper privateness rights past the preliminary platform to embody downstream information recipients.

California privacy law updates that took effect January 1, 2026 expanded necessities for companies to reveal whether or not private data classes are bought or shared at or earlier than the purpose of assortment. Corporations can not acquire extra classes of private data or use information for functions incompatible with preliminary disclosures with out offering up to date shopper discover.

The Disney case highlights basic questions on privateness implementation in streaming promoting. Whereas platforms have invested closely in promoting know-how infrastructure to maximise income alternatives, privateness compliance requires corresponding funding in programs that absolutely effectuate shopper opt-out selections throughout fragmented technical environments.

Corporations working streaming providers should consider present consent mechanisms, third-party relationships, and disclosure practices to make sure compliance with evolving necessities. The expanded scrutiny of technical implementation particulars suggests regulators will look at whether or not opt-out mechanisms perform as meant moderately than accepting surface-level compliance measures that depart gaps in precise information sharing practices.

Timeline

Abstract

Who: California Legal professional Basic Rob Bonta and The Walt Disney Firm, together with Disney DTC, LLC and ABC Enterprises, Inc., with jurisdiction exercised by the Superior Courtroom of the State of California, County of Los Angeles.

What: A $2.75 million settlement resolving allegations that Disney violated the California Shopper Privateness Act by failing to completely effectuate shoppers’ requests to opt-out of knowledge sale and sharing throughout all units and streaming providers related to shoppers’ Disney accounts. The settlement requires Disney to implement complete opt-out mechanisms that perform throughout Disney+, Hulu, ESPN+, and different Disney streaming providers, together with clear and conspicuous opt-out hyperlinks, correct dealing with of opt-out choice indicators, notifications to 3rd events, and a three-year compliance monitoring program with annual reporting to the Legal professional Basic.

When: The settlement was introduced on February 12, 2026, topic to courtroom approval. Disney should present compliance updates each 60 days till all providers adjust to necessities, implement a complete monitoring program inside 180 days, and preserve that program for 3 years. The $2.75 million civil penalty have to be paid inside 30 days of the efficient date.

The place: The enforcement motion covers Disney streaming providers accessible to California shoppers, together with Disney+, Hulu, and ESPN+, throughout all platforms together with sensible TVs, streaming units, gaming consoles, computer systems, cellular units, and tablets. Jurisdiction was established in Los Angeles Superior Courtroom, with the settlement affecting Disney’s operations nationwide as they serve California residents.

Why: The enforcement motion addresses failures in Disney’s technical implementation of privateness controls that left shoppers unable to completely opt-out of knowledge promoting and sharing regardless of making such requests. The opt-out toggle mechanism solely utilized requests to particular streaming providers and sometimes solely to particular units, whereas the webform mechanism solely stopped sharing by way of Disney’s personal promoting platform whereas persevering with to share information with third-party promoting know-how firms whose code Disney embedded in its platforms. The settlement goals to make sure Disney implements account-wide opt-out mechanisms that perform comprehensively throughout all units and providers, defending California shoppers’ statutory privateness rights whereas establishing compliance requirements for streaming platforms gathering and sharing private data for promoting functions.


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