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FTC Alleges COPPA Violations by Disney in Children's Privacy Enforcement Action

Disney Worldwide ServicesSeptember 2, 2025Federal Trade Commission

Summary

The FTC released a statement by Chairman Ferguson, joined by Commissioners Holyoak and Meador, regarding the enforcement action against Disney Worldwide Services for alleged violations of the Children's Online Privacy Protection Act (COPPA). The statement addresses the case involving children's privacy protections.

Contract Impact

In-house legal teams should review all agreements involving the collection or use of data from children under 13, including customer-facing terms of service, privacy policies, vendor contracts (especially with ad-tech or analytics providers), and any data processing agreements. Focus on clauses governing consent mechanisms (ensuring they are verifiable and parental), data collection purposes, data sharing with third parties (particularly for advertising), data retention and deletion policies for minors' data, and advertising practices targeting children. Contracts may need amendments to explicitly incorporate COPPA requirements, restrict profiling of children, mandate clear parental consent flows, limit data retention to the necessary period, and prohibit unauthorized data sharing. Ensure all marketing, analytics, and platform agreements with services potentially accessed by children contain robust COPPA-compliant provisions.

Contract Search Terms

parental consentchildren's privacy policydata collection from minorsCOPPA compliance clauseage verificationdata retention for minorsthird-party data sharing with children's dataadvertising to childrenverifiable parental consentchildren's data processing addendum

Laws Cited

Violation Types

Entity Details

Entity

Disney Worldwide Services

Also known as: Disney

Industry

Media & Entertainment

Official Sources

Source Evidence

Entity Name
"Disney Worldwide Servs."
Laws Cited
"Children's Online Privacy Protection Act (COPPA)"
Violation Types
"Children's Online Privacy Protection Act (COPPA)"

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