applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms. you may also refer to the summary of shanghai disney resort privacy policy. this summary is intended to provide you with an overview in a concise, clear and intelligible form about how we collect, use, share and protect your personal information through our app/wechat mini-program services.

this privacy policy also describes treatment of personal information collected by us through offline methods such as purchase of tickets or use of other services by guests at shanghai disney resort. we follow this privacy policy in accordance with applicable laws in the places where we operate. in some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. those terms are to be read in conjunction with this policy.

please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. the information that we collect is covered by this privacy policy, and the information that the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. we encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

  1. who we are
  2. types of information we collect and how we collect it
  3. permissions
  4. use of your information by shanghai disney resort
  5. sharing, entrusted processing or public disclosure of your information
  6. third-party services
  7. your controls and choices
  8. children’s privacy
  9. data security, integrity, and retention
  10. cross-border data transfers
  11. changes to this privacy policy
  12. comments and questions
  13. definitions
1. who we are
shanghai international theme park company limited (上海国际主题乐园有限公司) and shanghai international theme park associated facilities company limited (上海国际主题乐园配套设施有限公司) (collectively referred to as “shdr”or “we”) will be the personal information processors for your information.

2. types of information we collect and how we collect it
we collect two basic types of information – personal information (as defined in this privacy policy) and non-personal information (as defined in this privacy policy). we may collect the following categories of information under the circumstances as below (any sensitive personal information is highlighted in bold):

registration: you may register a shanghai disney resort user account (“user account”) through the shanghai disney resort official website (“shdr site”), or register a shanghai disney resort membership account (“membership account”) or upgrade your user account to membership account (“user account” and “membership account” collectively referred to as “shanghai disney resort account”) through shanghai disney resort official app (“shdr app”), and the shanghai disney resort official wechat account and shanghai disney resort wechat mini-programs (collectively “shdr wechat platform”). please check “shanghai disney resort membership terms and conditions” for the detailed information about the membership account.

when you register a shanghai disney resort account through the shdr site or shdr app, we will collect your mobile number in order to validate your identity and we get a confirmation from you that you are at age of 18 or above. when you use the shdr wechat platform, wechat will provide us with your wechat nickname, profile picture, and region upon your authorization. you may choose to voluntarily provide us with additional information, including your date of birth, name, country/region of residence, residence at provincial level, email address, and communication preferences, to enable us to have personalized communications with you, send you customized services and benefits (for example, birthday promotions), and conduct data analysis and provide custom features for you.

browsing or using shdr site, shdr app or shdr wechat platform: when you browse the shdr site, shdr app or shdr wechat platform without registering or logging in to your shanghai disney resort account, to comply with our legal obligations, safeguard cybersecurity and improve our services through collecting and analyzing users’ behavior, we will collect certain network log information, such as your device manufacturer, device model, internet access method (wifi or cellular network), operating system, operating system version, screen size, carrier, device id (e.g. android id, idfv, etc.), ip address, country/city information extracted through ip address analysis, your browsing and clicking history, date and time of operation, user’s wechat id information (if you use our services through wechat platform), system account (android only), and information about customer acquisition channels (e.g. the sources of advertisements you clicked on). if you log in to your shanghai disney resort account, we will also collect the above information, your activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences, and network logs information as required by law. in order to provide you with relevant special visual effect functions (e.g. augmented reality (ar) experience function) or make sure your device is compatible for certain services, we may collect your device sensor information (e.g., information related to gravity accelerometer, magnetometer, gyroscope and light sensor), as well as other information to the extent necessary for fulfilling special visual effect functions (e.g. non-identifiable face information for fulfilling the ar function when you take photos or record videos with special effects). if you grant location information permission for shdr app, we will also collect your location information to provide you with location-based services and information, including: to send push notifications to in-park guests in the event of emergencies or incidents (e.g., extreme weather); to enhance our map features (including locate you on the map, display nearby recreation facilities and services, etc.); to identify your presence in the park to provide you with the ar function; to display “book” or “discover” module on the landing page to guests outside or within the park respectively, to show your distance from the facilities and services on “bestsellers”, and to display content or distribute coupons that you may be interested in based on your location in the park, providing you with better user experience; and we may use statistical information that will not identify you for data analysis, in order to improve our services.

purchase/use of our services: we collect the following information (either online or offline) when you request to purchase products, services, or information from us. for example:feedback and guest survey: you may submit feedback in our visitor survey or interact with us through other means. if you choose to participate in the guest survey, you may voluntarily provide us with your personal information, and certain personal information about you may also be collected, based on business purposes, such as your gender, nationality, mobile number, email address, primary residence, domicile address, education background, family income range or age range of your children.

marketing service: if you choose to receive promotions and other relevant information from shdr and/or the walt disney family of companies, we will send you promotions, products and services from shdr and/or the walt disney family of companies, as well as recommendation of contents that you may be interested in via in-app notifications, email or sms. you may choose to opt out of such marketing messages at any time.

cookies and plug-ins: we collect information through a variety of technologies, such as cookies, flash cookies, pixels, tags, software development kits (“sdk”), application program interfaces, and web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered. when you are using our application or site, we may collect information on your device model, operating system, non-fixed device identifier, login ip address, and cache of your browsing and clicking history using cookies or similar technology, in order to review your network environment. through cookies, we may identify you when you visit our site, constantly improve our site to make it more user-friendly and make adjustments to our site based on your need. you may also change the settings of your browser to deny the use of cookies on our site, but this may affect your use of certain functions of our site.

third party cooperation: we acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we use third party courier services and need to verify postal address information, or when you book the tickets of shanghai disneyland or hotels or purchase the shanghai disneyland annual pass from third party travel providers, such service providers will transfer your personal information to us. for example, when you purchase the shanghai disneyland annual pass from a third party travel provider, such travel provider will share with us the necessary personal information to process your order for annual pass, including your name, government id number and mobile number, and after you successfully place your order, we will send your annual pass number and redemption password to the mobile number you filed in, for redemption purpose. when you purchase the tickets of shanghai disneyland, book our hotel rooms or purchase other products at our flagship store/direct-sale store on fliggy or jd, as appropriate, may share with us your name, nickname, government id number (such as id card number or passport number for the purpose of buying tickets), telephone number, and transaction information and invoice information about the products you purchased (if applicable). when you sign up for brand membership via our flagship store on tmall, tmall may share your taobao id, mobile number and other personal information with us, and when you shop at our flagship store on tmall, tmall may share with us your personal information to the extent necessary for fulfilling transaction purposes. we may use your personal information to provide you with services, including exclusive customer service, exclusive products and other special services, or to introduce our new products, services and activities to you. if you sign up for the membership as mentioned above, we may send you the latest news about shanghai disney resort and our tmall flagship store through channels including sms, ali wangwang, exclusive customer service and qingdian message; or when you shop or participate in other activities (such as luck draw or check-in activities) at our tmall flagship store, tmall may share your de-identified transaction information with us for data statistics and analysis and research of purchase preferences and trends, to help us improve our service, and to provide you with personalized content and services on tmall platform. applicable laws may require that you authorize the third party to share your information with us before we can acquire it.

ad-hoc activities and other scenarios: to invite you to our ad-hoc activities or offer you specific services, we may collect and process personal information from and about you based on your consent or any other legal basis for the personal information processing. for example, if you choose to participate in our ad-hoc activities (such as lucky draw), we will collect necessary personal information relevant to such activities from you, for example, your name, email address, mobile number, mailing address and/or your children’s information. the specific types of personal information to be collected will depend on the specific requirement for such activities or services.

the personal information that you provide about others: this privacy policy also applies to personal information you provide to us about third parties (for example, the personal information provided when you help others booking tickets). to the extent the information you provide contains personal information about others, you represent and warrant that you have informed relevant personal information subjects of this privacy policy and that you have received legal authorization from each subject.

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3. permissions
if you use shdr app, in order to collect your personal information as provided above, we will need to access certain permissions of your device as listed out below.

notification: in order to inform you of information related to the services we provide in a timely manner, we will ask for notification permission. if you use an ios device to open shdr app, we will ask for permission of notification when you open it for the first time, if you refuse such request, shdr app will not be able to provide in-app notifications to you; if you use an android device to open shdr app, we will pop-up a window to remind you that shdr app will send you in-app notifications when you open it for the first time, if you do not want to receive such notification, you may select the notification off option;

location information: we will ask for permission of the location information when you use the “map” function or ar experience function in the shdr app, so as to enhance our map features (incl., locate you on the map, display nearby recreation facilities and services, etc.) or identify your presence in the park to provide you with the ar function. we will also use your location information to provide you with other location-based services and information, including (i) to send app push notifications to in-park guests in the event of emergencies or incidents (e.g., extreme weather) and (ii) to display “book” or “discover” module on the homepage of the shdr app to guests outside or within the park respectively and show your distance from the facilities and services on “bestsellers”, and to display content or distribute coupons that you may be interested in based on your location in the park, providing you with better user experience. we may also use the statistical information that cannot identify you for data analysis, in order to improve our services. you may at any time turn off the authorization for geographical location data and refuse to provide such information, if you refuse to provide your location data, you can still use our map service, which, however, is only limited to display the location of the facilities and services on the map (without locating you on the map); but you will be unable to use ar experience function that we offer, receive location-based emergency notifications, or use the other functions as listed above.

recognition and log-in: we will ask for permission of touch id/face id for the purpose of quick login if you use an ios device to launch shdr app. you may refuse or turn off such permission and use regular login at any time;

camera: we will ask for permission of the camera when you use shdr app to scan a qr code for ticket linking. if you refuse to grant such permission, you will need to manually input the ticket id to link your ticket with your shdr account. we will ask for permission of the camera when you choose to take the profile photo for yourself or your child for redemption of an annual pass or to opt in to facial recognition park entry; if you refuse to grant such permission, you will not be able to take a profile photo and therefore, you will not be able to redeem an annual pass or opt in to facial recognition park entry in shdr app. we will also ask for permission of the camera when you use the featured ar experience function of the shdr app for the purpose of enabling you to take photos or record videos. if you refuse to grant such permission, you will not be able to use certain ar experience function that we offer.

album: we will ask for permission of saving and accessing to your album when you download pictures or videos from the shdr app or chose a picture in the album to identify it (e.g., identifying the ticket qr code or using the ar experience function) for the purpose of enabling you to save and identify such pictures or save videos in the album of your mobile phone. if you refuse to grant such permission, you will not be able to download or identify pictures from the shdr app or save videos.

microphone: we will ask for permission of the microphone when you record videos on the shdr app (e.g. using the ar experience function) for the purpose of enabling you to capture sound when recording videos. if you refuse to grant such permission, you will not be able to capture sound when you record videos on the shdr app.

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4. use of your information by shanghai disney resort
shanghai disney resort is the personal information processor for your information collected on the sites and applications where this privacy policy is posted and also personal information collected by us through offline methods at the shanghai disney resort. consistent with applicable laws and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:
  • in order to perform the contract with you;
  • provide you with the experiences, products, and services you request, view, engage with, or purchase;
  • fulfill obligations as required by applicable laws and regulations, and cooperate with orders and directives of courts and regulatory authorities;
  • communicate with you about your account or transactions with us and send you information or request feedback about our products or services or changes to our policies;
  • send you offers and promotions for our products and services or third-party products and services;
  • provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications;
  • operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including using guest survey research and analytics tools to analyze the effectiveness of advertisements;
  • detect, investigate and prevent activities that may violate our policies or be illegal, to protect the rights, property, and safety of shdr or others; and
  • protect our legitimate interests or public interests.

personalized recommendation service: to display and recommend products, services or content that are more relevant or of interest to you for the purpose of providing a personalized experience that better meets your needs, we may collect and process the following personal information to predict your preferences for personalized recommendations on the shdr app and shdr wechat platform: the personal information that you voluntarily provide to us when you create a shanghai disney resort account or use the services provided by shanghai disney resort, such as your date of birth, country/region of residence, residence at provincial level, etc.; your browsing and transaction history generated when you visit or use the shdr site, shdr app or shdr wechat platform; your device information (e.g., udi number (idfv, android_id), device model, operating system, and operating system name); your location information (e.g., your authorized location information, country/city information extracted through ip address analysis, and residence address you provided (if applicable)).

if you do not want us to display or recommend personalized products, services or content in the shdr app and shdr wechat platform, you can opt out of our personalized recommendation service through the method specified in section 7.3 of this privacy policy. if you do not want us to provide personalized content based on location information authorized by you, you can turn off location permissions through settings on your mobile phone.

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5. sharing, entrusted processing or public disclosure of your information
5.1 sharing your information

we will not share your personal information with a third party except in limited circumstances, including:
  • we may share your personal information as required by laws and regulations or as required by administrative or judicial authorities, or otherwise to perform our statutory duties or obligations;
  • we may share your personal information to respond to public health emergencies, or to protect the life, health and property security of natural persons in an emergency;
  • we may share your personal information which has been voluntarily disclosed by you to the public or other personal information that have been lawfully disclosed to the public;
  • when we provide your personal information with third parties in connection with merger, division, dissolution, bankruptcy, the sale of a business;
  • with your prior authorization: when you allow us to share your personal information with another company, such as:
    • sharing your personal information with the walt disney family of companies and/or its affiliated companies;
    • sharing your personal information with carefully selected companies so that they can provide you with their products and services or send you offers and promotions about their products and services;
    • directing us to share your personal information with third-party sites or platforms, such as social networking sites.
please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.

5.2 entrusted processing of your information

in order to provide services for you or effect the aforementioned purposes of use of information, we may entrust our affiliated entities, third-party service providers or partners to process your personal information. when such companies perform services on our behalf, like marketing and advertising, customer service, it service, data management and data analysis service, and insurance, insurance brokerage and loss adjustment services, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.

5.3 public disclosure of your information

we will not publicly disclose your personal information without your consent except in limited circumstances, including:
  • we may publicly disclose your information as required by laws and regulations or as required by administrative or judicial authorities, or otherwise to perform our statutory duties or obligations;
  • we may publicly disclose your information where it is necessary to respond to public health emergencies, or to protect the life, health and property security of natural persons in an emergency.
for details of the personal information our app and wechat mini-programs share with third parties, please refer to the list of personal information shared with third parties.

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6. third-party services
to provide and improve our online services, shdr app has embedded third-party sdks, which assist us in providing better services to you. security measures (such as encryption) have been taken for information transmission to such sdks. the privacy practices shall be referred to in the privacy policy of such third parties and such third parties will be liable for the security of your personal information collected by them. for detailed information about such sdks and plug-ins, please refer to the list of personal information shared with third parties.

to enhance your experiences, we also cooperate with third parties to provide you with certain services in shanghai disney resort, such as power bank rental service and locker service. under such circumstances, the third-party service providers will collect and process your personal information. the information that we collect is covered by this privacy policy, and the information that the third-party sites or platforms collect is subject to the third-party sites or platforms’ privacy practices.

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7. your controls and choices
we provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. in accordance with applicable laws, your controls and choices may include:

7.1 access, copy, correct supplement and delete your personal information

you may access, copy, correct and supplement or delete your personal information, and you may change your choices for subscription, newsletters and alerts. if you log into shdr site, you may enter your sign up page and modify relevant sections by clicking on the “welcome” button on the home page; if you log into shdr app, you may enter and edit your personal page and modify the relevant section by clicking “me-disney friend (profile picture)”; if you log into the shdr wechat platform, you may click “settings” (the gear button on the right side of your nickname) and access or edit your personal information. you may also contact us by hotline 400-180-0000 (mainland china) or 86-21-3158-0000 (all other countries/regions) or through email at shdr.privacy@disney.com to exercise your right to access, copy, correct, supplement or delete your personal information;

7.2 manage your message notifications

you may choose whether to receive offers and promotions for our products and services from us, or marketing communications regarding the products and services that we think may be of interest to you. if you log into shdr site, you may enter your personal page and manage your communication preferences by clicking “disney communications”; if you log into shdr app, you may manage your communication preferences by clicking “me” -> “general settings” -> “receive disney messages”; and if you log into shdr wechat platform, you may manage your marketing preferences by clicking “my center” -> “edit personal information” -> “receive disney messages”. under both circumstances, you may choose whether to receive offers, promotions and other marketing communications from shdr and the walt disney family of companies.

7.3 manage your personalized recommendation service

if you do not want us to display or recommend personalized products, services or content in the shdr app and shdr wechat platform, you can opt out of our personalized recommendation service through the following methods:
    - shdr app: “me” -> “general settings” -> “personalized recommendations”
    - shdr wechat platform: “my center” -> “edit personal information” -> “manage personalized recommendations”

7.4 change the scope of your authorization or withdraw your authorization
  • you may contact us at any time to withdraw your authorization and consent, including but not limited to opting out of facial recognition park entry;
  • you may deregister your account on shdr site, shdr app or shdr wechat platform in the account settings at any time, and we will delete such an account as soon as practicable. no matter if you log into the shdr site, shdr app or shdr wechat platform, you may enter your personal page and click “account settings-delete account”. you will be asked to enter your password or verification code and confirm to proceed. the deregistration of the account will result in an irrevocable removal of all of your user data and account information; provided that in specific cases, such as if reasonably necessary for the performance of our statutory obligations or for dispute resolution, we will retain your information in the back end for the period necessary to achieve such purposes after the deregistration of a user account. in addition, once deregistered, you will not be able to redeem or use via shdr site, shdr app or shdr wechat platform certain products or services (including without limitation the disney standby pass, coupons, the early park entry pass, the disney concierge services or the disney premier access) obtained or purchased by you (for details, please contact 400-1800000 (mainland china) or 86-21-3158-0000 (all other countries/regions), or send email to shdr.privacy@disney.com).
  • please be aware that if you do not allow us to collect personal information from you or you withdraw your consent or request for deleting your account, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. if collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.
  • if you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact the disney reservation center at 400-1800000 (mainland china) or 86-21-3158-0000 (all other countries/regions) or through email to shdr.privacy@disney.com, and we will reply to you within 15 working days from receipt of such an inquiry.

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8. children’s privacy

8.1 shdr site, shdr app and shdr wechat platform are age-gated so they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. when we intend to collect personal information of children, we ensure that we follow these principles including:
  • disclosing our information practices with regard to children, including the types of personal information of children we may collect, the uses to which we may put that information, and whether and with whom we may share that information;
  • to the extent required by applicable laws, obtaining consent from guardians for the collection of personal information of their children;
  • limiting our collection of personal information of children to no more than is reasonably necessary to provide our services, for example, children to participate in an activity, to comply with legal requirements or to achieve other legitimate purposes under the law; and
  • giving guardians access or the ability to request access to personal information of their children that we have collected and the ability to request that the personal information be corrected, supplemented or deleted according to law.
8.2 we will collect children’s personal information under the following circumstances:

  • when a child (accompanied by a guest aged 16 or older) enters shanghai disneyland, he or she will need to bring the original copy of government id, and we will collect the child’s name and the government id number and will take a photo of the child at the turnstile of shanghai disneyland;
  • in order to ensure the safety of our guests when they use recreation facilities, we have equipped our recreation facilities at shanghai disneyland with necessary photography, video and/or audio recording devices. these devices will capture photos or videos of children when they are using recreation facilities. in addition, for public safety purposes, we have installed multiple surveillance cameras within the shanghai disney resort, and as a result, photos or videos of children may be captured by these surveillance cameras;
  • when a guest redeems annual pass for his or her child, he or she will need to provide the name, government id number and take and submit to us a photo of such child for the purpose of identity verification for the annual pass; and the user opts in to facial recognition park entry for his or her child, he or she will need to take and submit to us a photo of such child for the purpose of park entry;
  • when a guest applies for ad hoc activities for his or her child, for example, if a guest would like his or her child to participate in disney inspiration run, we will collect the name, government id number, gender and date of birth of such child;
  • when a guest applies for complimentary vouchers, ticket refund, emergency healthcare service or other relevant services for his or her child, we will collect necessary and relevant personal information of such child. the specific types of personal information will depend on the specific circumstance of the service;
  • we need such information to protect our legitimate interests or public interests, for example, for the purpose of maintaining public security.
8.3 as a general principle, we do not share, disclose or transfer children’s personal information with/to third parties, expect when the sharing, entrusting, disclosure, or transfer is in compliance with the law or has been consented to by the guardians of the children. guardians may, by contacting us in accordance with this privacy policy, request us to correct a child’s personal information if finding such personal information collected or stored by us is erroneous or to delete children’s personal information.

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9. data security, integrity, and retention
9.1 the security, integrity, and confidentiality of your information are extremely important to us. we have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. we regularly review our security procedures to consider appropriate new technology and methods. please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

9.2 we have an emergency plan against network security incidents (including personal information related security incidents) to promptly deal with system bugs, computer viruses, network attacks, network invasions and other security risks. in case of an event with damage to the network security, we will immediately initiate the emergency plan, take relevant remedial measures and report to competent authorities as required by applicable laws and regulations. we will notify you in a timely manner of such event by sms, telephone, email or such other means of contact as provided by you. if it is difficult for us to notify the users one by one, we will make a public announcement through reasonable and effective means.

9.3 we will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law, and we will delete or anonymize your personal information upon expiry of that term.

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10. cross-border data transfer
we operate globally and will comply with legal requirements regarding cross-border data transfer. with your consent we may transfer your personal information to other companies within the walt disney family of companies or third parties in locations around the world for the purposes described in this privacy policy. wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. these steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information.

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11. changes to this privacy policy
this privacy policy shall come into effect as of the date first written above.

from time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. we will post notice of such changes on our sites and applications, or by other means, consistent with applicable laws. if these changes are material and, where required by applicable laws, we will obtain your consent. by continuing to browsing or use our services at shdr site, you consent to our updated privacy policy.

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12. comments and questions
for further information or enquiries regarding your personal information (including requesting access to, correction or deletion of your personal information or making a privacy complaint), please contact our disney reservation center at 400-1800000 (mainland china) or 86-21-3158-0000 (all other countries/regions) or through email at shdr.privacy@disney.com. we will reply your enquiries or complaint within 15 working days upon receipt.

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13. definitions
application
application means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile, or other platforms and environments, including those operated by third parties, which permits us to interact directly with our guests. the applications referred to in this privacy policy are all the latest versions thereof.

children
children means individuals under 18 years of age.

personal information processor
shanghai disney resort collects and processes the personal information collected on the site and applications where this privacy policy is posted and also personal information collected in our offline practices at the shanghai disney resort, and shanghai disney resort is the personal information processor as defined in the applicable laws or national standards of the people's republic of china.

ip address
an ip address is associated with the access point through which you enter the internet, and is typically controlled by your internet service provider (isp), your company, or your university. we may use ip addresses to collect information regarding the frequency with which our guests visit various parts of our sites and applications, and we may combine ip addresses with personal information.

non-personal information
non-personal information includes (i) anonymous information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest and (ii) aggregated information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual guest.

personal information
personal information means information related to an identified or identifiable natural person that is recorded electronically or otherwise, excluding anonymized information, such as the individual’s name, postal address, email address, and telephone number. when anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

sensitive personal information
sensitive personal information means personal information, the divulgence, illegal provision or misuse of which may endanger the bodily or property safety or may probably result in damage to personal dignity, which may be composed of information concerning race, religion, political position, personal health and physiological information, financial accounts, location tracking and other data, as well as the personal information of minors under the age of 14. in this privacy policy, sensitive personal information is marked in bold for your attention.

the walt disney family of companies
the walt disney family of companies refers to the walt disney company and its subsidiary and affiliated entities, which offer their products and services under various brand names. these companies engage in a number of businesses, including theme parks and travel, motion pictures and television, publishing, consumer products and interactive services. the walt disney company brands include, among others, the following:
  • abc entertainment
  • abc news
  • adventures by disney
  • aulani, a disney resort & spa
  • bamtech media
  • bindass
  • buena vista catalog company (including disney movie club)
  • d23 | the official disney fan club
  • disney baby
  • disney channels & disneynow
  • disney cruise line
  • disney digital network
  • disney family movies
  • disney movie insiders
  • disney on broadway
  • disney on ice and disney live!
  • disney photopass service
  • disney rewards visa card
  • disney vacation club
  • disney
  • disneyland paris
  • disneyland resort
  • disneylife
  • el capitan theatre
  • espn
  • espn cricinfo
  • espn deportes
  • espn
  • fivethirtyeight
  • freeform
  • fx networks
  • genx entertainment limited
  • hollywood records
  • hungama tv
  • lucasfilm (star wars)
  • marvel
  • marvel shop
  • marvel digital comics
  • muppets
  • pixar animation studios
  • radio disney
  • read riordan
  • shopdisney
  • the undefeated
  • 30 for 30 podcasts
  • united home entertainment private limited
  • utv software communication limited
  • walt disney pictures
  • walt disney studios home entertainment
  • walt disney world resort

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due to high demand, shanghai disney resort parking lots will be at or near full capacity during the weekends and holidays. guests visiting shanghai disneyland and disneytown are advised to take the metro, taxi or other public transportation.
zootopia has officially opened at shanghai disneyland on december 20. as we continue to manage maximum capacity for each area of our resort, and in anticipation of high demand to visit zootopia during its opening period, please understand that admission to zootopia or its new attraction “zootopia: hot pursuit” may not be secured for every guest who enters shanghai disneyland. however, guests will be able to encounter multiple new experiences with a zootopia touch throughout the park, including decoration, entertainment, food & beverage and merchandise.

please also note that overnight queuing for entry to shanghai disneyland on any day is not permitted. guests are encouraged to plan their trip accordingly.

in the opening phase, we expect that pauses and brief downtimes may occur from time to time in the new attraction “zootopia: hot pursuit”. downtimes may occur for a variety of reasons due to the complexity of the ride system and built-in safety features, based on industry requirements and best practices. in the event of downtime, guests will be required to evacuate according to onsite cast members' instructions. operation of the attraction will be resumed after the completion of all necessary procedures. we appreciate the understanding and cooperation of our guests during this opening period.
welcome to shanghai disney resort official website! our privacy policy and terms of use has been updated. please read it carefully.

privacy policy | shanghai disney resort-九游会电竞

last modified: dec 18, 2023

scope of this privacy policy

this privacy policy describes the treatment of personal information provided or collected on the sites and applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms. you may also refer to the summary of shanghai disney resort privacy policy. this summary is intended to provide you with an overview in a concise, clear and intelligible form about how we collect, use, share and protect your personal information through our app/wechat mini-program services.

this privacy policy also describes treatment of personal information collected by us through offline methods such as purchase of tickets or use of other services by guests at shanghai disney resort. we follow this privacy policy in accordance with applicable laws in the places where we operate. in some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. those terms are to be read in conjunction with this policy.

please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. the information that we collect is covered by this privacy policy, and the information that the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. we encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

  1. who we are
  2. types of information we collect and how we collect it
  3. permissions
  4. use of your information by shanghai disney resort
  5. sharing, entrusted processing or public disclosure of your information
  6. third-party services
  7. your controls and choices
  8. children’s privacy
  9. data security, integrity, and retention
  10. cross-border data transfers
  11. changes to this privacy policy
  12. comments and questions
  13. definitions
1. who we are
shanghai international theme park company limited (上海国际主题乐园有限公司) and shanghai international theme park associated facilities company limited (上海国际主题乐园配套设施有限公司) (collectively referred to as “shdr”or “we”) will be the personal information processors for your information.

2. types of information we collect and how we collect it
we collect two basic types of information – personal information (as defined in this privacy policy) and non-personal information (as defined in this privacy policy). we may collect the following categories of information under the circumstances as below (any sensitive personal information is highlighted in bold):

registration: you may register a shanghai disney resort user account (“user account”) through the shanghai disney resort official website (“shdr site”), or register a shanghai disney resort membership account (“membership account”) or upgrade your user account to membership account (“user account” and “membership account” collectively referred to as “shanghai disney resort account”) through shanghai disney resort official app (“shdr app”), and the shanghai disney resort official wechat account and shanghai disney resort wechat mini-programs (collectively “shdr wechat platform”). please check “shanghai disney resort membership terms and conditions” for the detailed information about the membership account.

when you register a shanghai disney resort account through the shdr site or shdr app, we will collect your mobile number in order to validate your identity and we get a confirmation from you that you are at age of 18 or above. when you use the shdr wechat platform, wechat will provide us with your wechat nickname, profile picture, and region upon your authorization. you may choose to voluntarily provide us with additional information, including your date of birth, name, country/region of residence, residence at provincial level, email address, and communication preferences, to enable us to have personalized communications with you, send you customized services and benefits (for example, birthday promotions), and conduct data analysis and provide custom features for you.

browsing or using shdr site, shdr app or shdr wechat platform: when you browse the shdr site, shdr app or shdr wechat platform without registering or logging in to your shanghai disney resort account, to comply with our legal obligations, safeguard cybersecurity and improve our services through collecting and analyzing users’ behavior, we will collect certain network log information, such as your device manufacturer, device model, internet access method (wifi or cellular network), operating system, operating system version, screen size, carrier, device id (e.g. android id, idfv, etc.), ip address, country/city information extracted through ip address analysis, your browsing and clicking history, date and time of operation, user’s wechat id information (if you use our services through wechat platform), system account (android only), and information about customer acquisition channels (e.g. the sources of advertisements you clicked on). if you log in to your shanghai disney resort account, we will also collect the above information, your activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences, and network logs information as required by law. in order to provide you with relevant special visual effect functions (e.g. augmented reality (ar) experience function) or make sure your device is compatible for certain services, we may collect your device sensor information (e.g., information related to gravity accelerometer, magnetometer, gyroscope and light sensor), as well as other information to the extent necessary for fulfilling special visual effect functions (e.g. non-identifiable face information for fulfilling the ar function when you take photos or record videos with special effects). if you grant location information permission for shdr app, we will also collect your location information to provide you with location-based services and information, including: to send push notifications to in-park guests in the event of emergencies or incidents (e.g., extreme weather); to enhance our map features (including locate you on the map, display nearby recreation facilities and services, etc.); to identify your presence in the park to provide you with the ar function; to display “book” or “discover” module on the landing page to guests outside or within the park respectively, to show your distance from the facilities and services on “bestsellers”, and to display content or distribute coupons that you may be interested in based on your location in the park, providing you with better user experience; and we may use statistical information that will not identify you for data analysis, in order to improve our services.

purchase/use of our services: we collect the following information (either online or offline) when you request to purchase products, services, or information from us. for example:
  • buy tickets or annual passes: when you buy tickets or annual passes for shanghai disneyland, we will collect your name, government id number (such as id card number or passport number), mobile number or email address.
  • enter shanghai disneyland: when you enter shanghai disneyland, we will collect your name and government id number.
  • buy disney premier access, the early park entry pass or other benefits: when you buy the disney premier access, the early park entry pass or other benefits (including but not limited to the disney concierge services, disney premier tour), we will collect your name, government id number, mobile number or email address.
  • booking hotel: when you book our hotel, we will collect your name, mobile number or email address.
  • payment: if you make payments through shdr site, shdr app or shdr wechat platform, we will collect your transaction and consumption records, wechat open id or alipay de-identified account information.
  • invoicing: when you request a vat invoice for the product or service we provide, we will collect the information necessary for us to issue invoice, including purchaser’s name and taxpayer identification number (for businesses and government institutions only); if you request a special vat invoice, we will further collect the company name, business address, taxpayer identification number, telephone number, bank name and bank account number of the purchaser. in addition, in order to send electronic or physical invoices, we will also collect your receipt details (e.g., telephone number or email address for receiving electronic invoices) or mailing information (e.g. mailing address for delivering physical invoices). any of such personal information we collect from you will only be used for the purposes of issuing and sending invoices.
  • using map search services: when you are using the “map” function in the shdr app, upon your authorization, we will collect your geographical location data, so that we may locate you on the map and present to you the nearest recreation facilities and services, and you may at any time turn off the authorization for geographical location data and refuse to provide such information, without affecting your use of our other services.
  • annual passes redemption: to redeem your shanghai disneyland annual pass in the shdr app (“online redemption”), you will need to provide necessary identity information (including your name, your government id number, your age details for verifying your eligibility to use certain services and a photo of your government id) and take and submit a profile photo via shdr app. we will utilize facial recognition technology to verify your identity by comparing such profile photo against your photo on your government id. we will not store the photo of your government id once your identity has been verified. you also have the option for online redemption of the annual pass for your child under the age of 18. when you redeem annual pass for your child, you will be asked to manually input the child’s name, government id number (including your child’s age details for verifying your child’s eligibility to use certain services), and take and submit a profile photo of your child. the personal information you provide to us, including name, government id number and profile photo of you and/or your child, will be stored and linked to the annual pass redeemed and used to confirm identity when you or your child enters shanghai disneyland. you may also choose to go to the shanghai disneyland in person with your government id and other documents required by us to redeem your annual pass onsite.
  • facial recognition park entry for annual pass holder: further, when you, as an annual pass holder, opt in to facial recognition park entry in the shdr app to enjoy convenient park entry for yourself or your child under the age of 18, you will need to take and upload to the shdr app a profile photo of yourself or your child, as applicable. this photo will be stored and will only be used for park entry purpose. once opted in to facial recognition park entry, you / your child can enter the shanghai disneyland through the designated facial recognition lanes. the facial recognition system installed in the turnstiles of the designated facial recognition lanes will capture your/your child’s facial images and we will utilize facial recognition technology to verify your/your child’s identity by comparing such photo taken at the turnstiles against your/your child’s profile photo previously uploaded during opt-in in the shdr app. the photo taken at the turnstiles in the designated facial recognition lanes will only be used for park entry purpose and will be deleted from the facial recognition system at the end of the day of such photo capturing. if you choose not to opt in to facial recognition park entry, the annual pass can still be used for you to access shanghai disneyland normally. however, the facial recognition system in the facial recognition lanes may still capture your facial images if you choose to walk through such lanes (but all photos will be deleted at the end of the day of such photo capturing).
  • wifi services: if you choose to use wifi services provided at shanghai disneyland, then we will collect the mac address of your device and your mobile number for complying with the relevant legal requirements.
  • hotline /email services/customer service on wechat: if you choose to make ticket booking, hotel or catering booking, consultation, complaint or reservation of certain products or services (such as disney concierge service, disney premier tour, disney fairy tale wedding, etc.) via our hotline or email services, you may need to provide relevant personal information according to the services you request for or for us to verify your identity, for example, your email address, name, mobile number or government id number. if you choose to use our hotline services, we will also need to record the conversations in our hotlines for services quality assurance, internal training, public security protection and other directly related purpose. if you send inquiries, make reservations or file complaints through customer service at our wechat official account, you may choose to provide us with your mobile number, to enable us to keep track of your service progress, access your inquiry history, and provide better and more efficient customer service.
  • other shanghai disney resort services:when you are in shanghai disney resort, we will provide you with various types of services. in order to identify your identity and provide you with certain services (such as park re-entry, disney premium access, disney standby pass service), we will take a photo of you at the turnstile of the shanghai disneyland. your photo taken at the turnstile may also be used by us for administrative and internal or external investigation purposes where necessary. we have installed multiple cameras in the shanghai disney resort for public security purpose, therefore, after you enter the shanghai disney resort, you will enter the recording area and you may be taken photos or recorded videos by such cameras. but such information will not be used for any purpose other than safeguarding public safety. we have equipped our recreation facilities at shanghai disneyland with necessary photography, video and/or audio recording devices; these devices are used for monitoring the facilities operations and guest activities on the facilities, to identify and avoid any dangerous situation, in order to ensure the safe operation of the facilities and the safety of our guests when they use these facilities. we will also collect your personal information as necessary for providing hotel service and other ancillary services such as luggage deposit and vehicle parking services.
    your image may be captured when you interact with stitch at the stitch encounter in the shanghai disneyland, but your image will only be used during the show and will be deleted immediately after the show.
  • disney photopass service: when you enjoy attractions such as tron lightcycle power run, buzz lightyear planet rescue, pirates of the caribbean: battle for the sunken treasure, and zootopia: hot pursuit in the shanghai disneyland, as part of the experience, fun photos of you may be captured by the automated imaging facility to save your enjoyable moment in the shanghai disneyland. we also offer disney photopass service at photopass locations in the shanghai disneyland and the shanghai disneyland hotel. disney photopass photographers may capture your photos when you meet with disney characters and enjoy your time in the park and at the hotel. you may visit to learn about how the vendor of disney photopass service processes and protects your personal information (including but not limited to your photos).
  • shanghai disney resort mobile order platform: when you use and browse the shanghai disney resort mobile order platform, we will collect certain information about your device (including device manufacturer, device system, operating system version, browser name, browser version, screen size, device model, device language, ip address, and country/city information extracted through ip address analysis) and openid (for wechat browser only). if you place an order under visitor mode, you may input your mobile number in order to receive sms for order pickup, and we will not collect any additional personal information. if you have a shanghai disney resort account, you may sign in your account and place an order, and we will record the mobile number associated with your account for you to quickly access and use the coupons in your account (if available), to view the order history under your account and to receive sms for order pickup.
  • shanghai disney resort dining and shopping virtual queuing: when you use the shanghai disney resort dinning and shopping virtual queuing wechat mini program, we will collect your openid to complete the online queuing process, and upon your authorization, to send service notifications via the wechat mini program to keep you informed of queue status. when a merchant on the shanghai disney resort dinning and shopping virtual queuing wechat mini program only allows users within a certain distance from the merchant to queue online, upon your authorization, we will need to obtain your location information solely for the purpose of confirming whether you are within the range set by the merchant, in order to provide you with the online queuing service.
  • shanghai disneyland zootopia in your paw: when you use the shanghai disneyland zootopia in your paw (“zootopia in your paw”) wechat mini-program, we will collect information about your device (including device manufacturer, device system, operating system version, browser name, browser version, screen size, device model, device language, ip address, and country/city information extracted through ip address analysis), openid, and browsing history; when you apply for a zootizen id, you may choose to fill in your date of birth and we may provide you with customized services or benefits.
    when you use zootopia in your paw in shdr app, we will collect information about your device (including, device manufacturer, device system, operating system version, browser name, browser version, screen size, device model, device language, ip address, and country/city information extracted through ip address analysis) and browsing history. when you apply for a zootizen id, you may choose to fill in your date of birth and we may provide you with customized services or benefits (such as birthday lens). when you use the ar camera to take photos or videos, we may request your permission to access your camera, microphone or photo album when necessary (please refer to “section 3. permissions” of this privacy policy for more details); because some of the lens provided by the aforementioned ar feature are only available within the park or within zootopia, when you are using the feature, we will need to access your location information to determine whether you are in the park or zootopia in order to provide you with lens that are available in a particular area; in addition, when you take a photo or video using the ar lens, we need to collect your facial images for face detection, which is used to recognize the position of the face in the shot, in order to provide the face beauty, face sticker lens and character following lens (however, we will not extract facial features from the faces that we have detected or perform facial comparison, and the facial detection is performed locally on your device and we will not save your facial images or upload the same to the cloud). stroll around zootopia is only available in zootopia, so when you use stroll around zootopia we need to access your location information to determine whether you are in zootopia or not, and we also need to access your camera to recognize specific buildings in zootopia during your missions.
feedback and guest survey: you may submit feedback in our visitor survey or interact with us through other means. if you choose to participate in the guest survey, you may voluntarily provide us with your personal information, and certain personal information about you may also be collected, based on business purposes, such as your gender, nationality, mobile number, email address, primary residence, domicile address, education background, family income range or age range of your children.

marketing service: if you choose to receive promotions and other relevant information from shdr and/or the walt disney family of companies, we will send you promotions, products and services from shdr and/or the walt disney family of companies, as well as recommendation of contents that you may be interested in via in-app notifications, email or sms. you may choose to opt out of such marketing messages at any time.

cookies and plug-ins: we collect information through a variety of technologies, such as cookies, flash cookies, pixels, tags, software development kits (“sdk”), application program interfaces, and web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered. when you are using our application or site, we may collect information on your device model, operating system, non-fixed device identifier, login ip address, and cache of your browsing and clicking history using cookies or similar technology, in order to review your network environment. through cookies, we may identify you when you visit our site, constantly improve our site to make it more user-friendly and make adjustments to our site based on your need. you may also change the settings of your browser to deny the use of cookies on our site, but this may affect your use of certain functions of our site.

third party cooperation: we acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we use third party courier services and need to verify postal address information, or when you book the tickets of shanghai disneyland or hotels or purchase the shanghai disneyland annual pass from third party travel providers, such service providers will transfer your personal information to us. for example, when you purchase the shanghai disneyland annual pass from a third party travel provider, such travel provider will share with us the necessary personal information to process your order for annual pass, including your name, government id number and mobile number, and after you successfully place your order, we will send your annual pass number and redemption password to the mobile number you filed in, for redemption purpose. when you purchase the tickets of shanghai disneyland, book our hotel rooms or purchase other products at our flagship store/direct-sale store on fliggy or jd, as appropriate, may share with us your name, nickname, government id number (such as id card number or passport number for the purpose of buying tickets), telephone number, and transaction information and invoice information about the products you purchased (if applicable). when you sign up for brand membership via our flagship store on tmall, tmall may share your taobao id, mobile number and other personal information with us, and when you shop at our flagship store on tmall, tmall may share with us your personal information to the extent necessary for fulfilling transaction purposes. we may use your personal information to provide you with services, including exclusive customer service, exclusive products and other special services, or to introduce our new products, services and activities to you. if you sign up for the membership as mentioned above, we may send you the latest news about shanghai disney resort and our tmall flagship store through channels including sms, ali wangwang, exclusive customer service and qingdian message; or when you shop or participate in other activities (such as luck draw or check-in activities) at our tmall flagship store, tmall may share your de-identified transaction information with us for data statistics and analysis and research of purchase preferences and trends, to help us improve our service, and to provide you with personalized content and services on tmall platform. applicable laws may require that you authorize the third party to share your information with us before we can acquire it.

ad-hoc activities and other scenarios: to invite you to our ad-hoc activities or offer you specific services, we may collect and process personal information from and about you based on your consent or any other legal basis for the personal information processing. for example, if you choose to participate in our ad-hoc activities (such as lucky draw), we will collect necessary personal information relevant to such activities from you, for example, your name, email address, mobile number, mailing address and/or your children’s information. the specific types of personal information to be collected will depend on the specific requirement for such activities or services.

the personal information that you provide about others: this privacy policy also applies to personal information you provide to us about third parties (for example, the personal information provided when you help others booking tickets). to the extent the information you provide contains personal information about others, you represent and warrant that you have informed relevant personal information subjects of this privacy policy and that you have received legal authorization from each subject.

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3. permissions
if you use shdr app, in order to collect your personal information as provided above, we will need to access certain permissions of your device as listed out below.

notification: in order to inform you of information related to the services we provide in a timely manner, we will ask for notification permission. if you use an ios device to open shdr app, we will ask for permission of notification when you open it for the first time, if you refuse such request, shdr app will not be able to provide in-app notifications to you; if you use an android device to open shdr app, we will pop-up a window to remind you that shdr app will send you in-app notifications when you open it for the first time, if you do not want to receive such notification, you may select the notification off option;

location information: we will ask for permission of the location information when you use the “map” function or ar experience function in the shdr app, so as to enhance our map features (incl., locate you on the map, display nearby recreation facilities and services, etc.) or identify your presence in the park to provide you with the ar function. we will also use your location information to provide you with other location-based services and information, including (i) to send app push notifications to in-park guests in the event of emergencies or incidents (e.g., extreme weather) and (ii) to display “book” or “discover” module on the homepage of the shdr app to guests outside or within the park respectively and show your distance from the facilities and services on “bestsellers”, and to display content or distribute coupons that you may be interested in based on your location in the park, providing you with better user experience. we may also use the statistical information that cannot identify you for data analysis, in order to improve our services. you may at any time turn off the authorization for geographical location data and refuse to provide such information, if you refuse to provide your location data, you can still use our map service, which, however, is only limited to display the location of the facilities and services on the map (without locating you on the map); but you will be unable to use ar experience function that we offer, receive location-based emergency notifications, or use the other functions as listed above.

recognition and log-in: we will ask for permission of touch id/face id for the purpose of quick login if you use an ios device to launch shdr app. you may refuse or turn off such permission and use regular login at any time;

camera: we will ask for permission of the camera when you use shdr app to scan a qr code for ticket linking. if you refuse to grant such permission, you will need to manually input the ticket id to link your ticket with your shdr account. we will ask for permission of the camera when you choose to take the profile photo for yourself or your child for redemption of an annual pass or to opt in to facial recognition park entry; if you refuse to grant such permission, you will not be able to take a profile photo and therefore, you will not be able to redeem an annual pass or opt in to facial recognition park entry in shdr app. we will also ask for permission of the camera when you use the featured ar experience function of the shdr app for the purpose of enabling you to take photos or record videos. if you refuse to grant such permission, you will not be able to use certain ar experience function that we offer.

album: we will ask for permission of saving and accessing to your album when you download pictures or videos from the shdr app or chose a picture in the album to identify it (e.g., identifying the ticket qr code or using the ar experience function) for the purpose of enabling you to save and identify such pictures or save videos in the album of your mobile phone. if you refuse to grant such permission, you will not be able to download or identify pictures from the shdr app or save videos.

microphone: we will ask for permission of the microphone when you record videos on the shdr app (e.g. using the ar experience function) for the purpose of enabling you to capture sound when recording videos. if you refuse to grant such permission, you will not be able to capture sound when you record videos on the shdr app.

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4. use of your information by shanghai disney resort
shanghai disney resort is the personal information processor for your information collected on the sites and applications where this privacy policy is posted and also personal information collected by us through offline methods at the shanghai disney resort. consistent with applicable laws and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:
  • in order to perform the contract with you;
  • provide you with the experiences, products, and services you request, view, engage with, or purchase;
  • fulfill obligations as required by applicable laws and regulations, and cooperate with orders and directives of courts and regulatory authorities;
  • communicate with you about your account or transactions with us and send you information or request feedback about our products or services or changes to our policies;
  • send you offers and promotions for our products and services or third-party products and services;
  • provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications;
  • operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including using guest survey research and analytics tools to analyze the effectiveness of advertisements;
  • detect, investigate and prevent activities that may violate our policies or be illegal, to protect the rights, property, and safety of shdr or others; and
  • protect our legitimate interests or public interests.

personalized recommendation service: to display and recommend products, services or content that are more relevant or of interest to you for the purpose of providing a personalized experience that better meets your needs, we may collect and process the following personal information to predict your preferences for personalized recommendations on the shdr app and shdr wechat platform: the personal information that you voluntarily provide to us when you create a shanghai disney resort account or use the services provided by shanghai disney resort, such as your date of birth, country/region of residence, residence at provincial level, etc.; your browsing and transaction history generated when you visit or use the shdr site, shdr app or shdr wechat platform; your device information (e.g., udi number (idfv, android_id), device model, operating system, and operating system name); your location information (e.g., your authorized location information, country/city information extracted through ip address analysis, and residence address you provided (if applicable)).

if you do not want us to display or recommend personalized products, services or content in the shdr app and shdr wechat platform, you can opt out of our personalized recommendation service through the method specified in section 7.3 of this privacy policy. if you do not want us to provide personalized content based on location information authorized by you, you can turn off location permissions through settings on your mobile phone.

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5. sharing, entrusted processing or public disclosure of your information
5.1 sharing your information

we will not share your personal information with a third party except in limited circumstances, including:
  • we may share your personal information as required by laws and regulations or as required by administrative or judicial authorities, or otherwise to perform our statutory duties or obligations;
  • we may share your personal information to respond to public health emergencies, or to protect the life, health and property security of natural persons in an emergency;
  • we may share your personal information which has been voluntarily disclosed by you to the public or other personal information that have been lawfully disclosed to the public;
  • when we provide your personal information with third parties in connection with merger, division, dissolution, bankruptcy, the sale of a business;
  • with your prior authorization: when you allow us to share your personal information with another company, such as:
    • sharing your personal information with the walt disney family of companies and/or its affiliated companies;
    • sharing your personal information with carefully selected companies so that they can provide you with their products and services or send you offers and promotions about their products and services;
    • directing us to share your personal information with third-party sites or platforms, such as social networking sites.
please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.

5.2 entrusted processing of your information

in order to provide services for you or effect the aforementioned purposes of use of information, we may entrust our affiliated entities, third-party service providers or partners to process your personal information. when such companies perform services on our behalf, like marketing and advertising, customer service, it service, data management and data analysis service, and insurance, insurance brokerage and loss adjustment services, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.

5.3 public disclosure of your information

we will not publicly disclose your personal information without your consent except in limited circumstances, including:
  • we may publicly disclose your information as required by laws and regulations or as required by administrative or judicial authorities, or otherwise to perform our statutory duties or obligations;
  • we may publicly disclose your information where it is necessary to respond to public health emergencies, or to protect the life, health and property security of natural persons in an emergency.
for details of the personal information our app and wechat mini-programs share with third parties, please refer to the list of personal information shared with third parties.

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6. third-party services
to provide and improve our online services, shdr app has embedded third-party sdks, which assist us in providing better services to you. security measures (such as encryption) have been taken for information transmission to such sdks. the privacy practices shall be referred to in the privacy policy of such third parties and such third parties will be liable for the security of your personal information collected by them. for detailed information about such sdks and plug-ins, please refer to the list of personal information shared with third parties.

to enhance your experiences, we also cooperate with third parties to provide you with certain services in shanghai disney resort, such as power bank rental service and locker service. under such circumstances, the third-party service providers will collect and process your personal information. the information that we collect is covered by this privacy policy, and the information that the third-party sites or platforms collect is subject to the third-party sites or platforms’ privacy practices.

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7. your controls and choices
we provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. in accordance with applicable laws, your controls and choices may include:

7.1 access, copy, correct supplement and delete your personal information

you may access, copy, correct and supplement or delete your personal information, and you may change your choices for subscription, newsletters and alerts. if you log into shdr site, you may enter your sign up page and modify relevant sections by clicking on the “welcome” button on the home page; if you log into shdr app, you may enter and edit your personal page and modify the relevant section by clicking “me-disney friend (profile picture)”; if you log into the shdr wechat platform, you may click “settings” (the gear button on the right side of your nickname) and access or edit your personal information. you may also contact us by hotline 400-180-0000 (mainland china) or 86-21-3158-0000 (all other countries/regions) or through email at shdr.privacy@disney.com to exercise your right to access, copy, correct, supplement or delete your personal information;

7.2 manage your message notifications

you may choose whether to receive offers and promotions for our products and services from us, or marketing communications regarding the products and services that we think may be of interest to you. if you log into shdr site, you may enter your personal page and manage your communication preferences by clicking “disney communications”; if you log into shdr app, you may manage your communication preferences by clicking “me” -> “general settings” -> “receive disney messages”; and if you log into shdr wechat platform, you may manage your marketing preferences by clicking “my center” -> “edit personal information” -> “receive disney messages”. under both circumstances, you may choose whether to receive offers, promotions and other marketing communications from shdr and the walt disney family of companies.

7.3 manage your personalized recommendation service

if you do not want us to display or recommend personalized products, services or content in the shdr app and shdr wechat platform, you can opt out of our personalized recommendation service through the following methods:
    - shdr app: “me” -> “general settings” -> “personalized recommendations”
    - shdr wechat platform: “my center” -> “edit personal information” -> “manage personalized recommendations”

7.4 change the scope of your authorization or withdraw your authorization
  • you may contact us at any time to withdraw your authorization and consent, including but not limited to opting out of facial recognition park entry;
  • you may deregister your account on shdr site, shdr app or shdr wechat platform in the account settings at any time, and we will delete such an account as soon as practicable. no matter if you log into the shdr site, shdr app or shdr wechat platform, you may enter your personal page and click “account settings-delete account”. you will be asked to enter your password or verification code and confirm to proceed. the deregistration of the account will result in an irrevocable removal of all of your user data and account information; provided that in specific cases, such as if reasonably necessary for the performance of our statutory obligations or for dispute resolution, we will retain your information in the back end for the period necessary to achieve such purposes after the deregistration of a user account. in addition, once deregistered, you will not be able to redeem or use via shdr site, shdr app or shdr wechat platform certain products or services (including without limitation the disney standby pass, coupons, the early park entry pass, the disney concierge services or the disney premier access) obtained or purchased by you (for details, please contact 400-1800000 (mainland china) or 86-21-3158-0000 (all other countries/regions), or send email to shdr.privacy@disney.com).
  • please be aware that if you do not allow us to collect personal information from you or you withdraw your consent or request for deleting your account, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. if collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.
  • if you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact the disney reservation center at 400-1800000 (mainland china) or 86-21-3158-0000 (all other countries/regions) or through email to shdr.privacy@disney.com, and we will reply to you within 15 working days from receipt of such an inquiry.

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8. children’s privacy

8.1 shdr site, shdr app and shdr wechat platform are age-gated so they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. when we intend to collect personal information of children, we ensure that we follow these principles including:
  • disclosing our information practices with regard to children, including the types of personal information of children we may collect, the uses to which we may put that information, and whether and with whom we may share that information;
  • to the extent required by applicable laws, obtaining consent from guardians for the collection of personal information of their children;
  • limiting our collection of personal information of children to no more than is reasonably necessary to provide our services, for example, children to participate in an activity, to comply with legal requirements or to achieve other legitimate purposes under the law; and
  • giving guardians access or the ability to request access to personal information of their children that we have collected and the ability to request that the personal information be corrected, supplemented or deleted according to law.
8.2 we will collect children’s personal information under the following circumstances:

  • when a child (accompanied by a guest aged 16 or older) enters shanghai disneyland, he or she will need to bring the original copy of government id, and we will collect the child’s name and the government id number and will take a photo of the child at the turnstile of shanghai disneyland;
  • in order to ensure the safety of our guests when they use recreation facilities, we have equipped our recreation facilities at shanghai disneyland with necessary photography, video and/or audio recording devices. these devices will capture photos or videos of children when they are using recreation facilities. in addition, for public safety purposes, we have installed multiple surveillance cameras within the shanghai disney resort, and as a result, photos or videos of children may be captured by these surveillance cameras;
  • when a guest redeems annual pass for his or her child, he or she will need to provide the name, government id number and take and submit to us a photo of such child for the purpose of identity verification for the annual pass; and the user opts in to facial recognition park entry for his or her child, he or she will need to take and submit to us a photo of such child for the purpose of park entry;
  • when a guest applies for ad hoc activities for his or her child, for example, if a guest would like his or her child to participate in disney inspiration run, we will collect the name, government id number, gender and date of birth of such child;
  • when a guest applies for complimentary vouchers, ticket refund, emergency healthcare service or other relevant services for his or her child, we will collect necessary and relevant personal information of such child. the specific types of personal information will depend on the specific circumstance of the service;
  • we need such information to protect our legitimate interests or public interests, for example, for the purpose of maintaining public security.
8.3 as a general principle, we do not share, disclose or transfer children’s personal information with/to third parties, expect when the sharing, entrusting, disclosure, or transfer is in compliance with the law or has been consented to by the guardians of the children. guardians may, by contacting us in accordance with this privacy policy, request us to correct a child’s personal information if finding such personal information collected or stored by us is erroneous or to delete children’s personal information.

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9. data security, integrity, and retention
9.1 the security, integrity, and confidentiality of your information are extremely important to us. we have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. we regularly review our security procedures to consider appropriate new technology and methods. please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

9.2 we have an emergency plan against network security incidents (including personal information related security incidents) to promptly deal with system bugs, computer viruses, network attacks, network invasions and other security risks. in case of an event with damage to the network security, we will immediately initiate the emergency plan, take relevant remedial measures and report to competent authorities as required by applicable laws and regulations. we will notify you in a timely manner of such event by sms, telephone, email or such other means of contact as provided by you. if it is difficult for us to notify the users one by one, we will make a public announcement through reasonable and effective means.

9.3 we will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law, and we will delete or anonymize your personal information upon expiry of that term.

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10. cross-border data transfer
we operate globally and will comply with legal requirements regarding cross-border data transfer. with your consent we may transfer your personal information to other companies within the walt disney family of companies or third parties in locations around the world for the purposes described in this privacy policy. wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. these steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information.

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11. changes to this privacy policy
this privacy policy shall come into effect as of the date first written above.

from time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. we will post notice of such changes on our sites and applications, or by other means, consistent with applicable laws. if these changes are material and, where required by applicable laws, we will obtain your consent. by continuing to browsing or use our services at shdr site, you consent to our updated privacy policy.

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12. comments and questions
for further information or enquiries regarding your personal information (including requesting access to, correction or deletion of your personal information or making a privacy complaint), please contact our disney reservation center at 400-1800000 (mainland china) or 86-21-3158-0000 (all other countries/regions) or through email at shdr.privacy@disney.com. we will reply your enquiries or complaint within 15 working days upon receipt.

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13. definitions
application
application means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile, or other platforms and environments, including those operated by third parties, which permits us to interact directly with our guests. the applications referred to in this privacy policy are all the latest versions thereof.

children
children means individuals under 18 years of age.

personal information processor
shanghai disney resort collects and processes the personal information collected on the site and applications where this privacy policy is posted and also personal information collected in our offline practices at the shanghai disney resort, and shanghai disney resort is the personal information processor as defined in the applicable laws or national standards of the people's republic of china.

ip address
an ip address is associated with the access point through which you enter the internet, and is typically controlled by your internet service provider (isp), your company, or your university. we may use ip addresses to collect information regarding the frequency with which our guests visit various parts of our sites and applications, and we may combine ip addresses with personal information.

non-personal information
non-personal information includes (i) anonymous information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest and (ii) aggregated information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual guest.

personal information
personal information means information related to an identified or identifiable natural person that is recorded electronically or otherwise, excluding anonymized information, such as the individual’s name, postal address, email address, and telephone number. when anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

sensitive personal information
sensitive personal information means personal information, the divulgence, illegal provision or misuse of which may endanger the bodily or property safety or may probably result in damage to personal dignity, which may be composed of information concerning race, religion, political position, personal health and physiological information, financial accounts, location tracking and other data, as well as the personal information of minors under the age of 14. in this privacy policy, sensitive personal information is marked in bold for your attention.

the walt disney family of companies
the walt disney family of companies refers to the walt disney company and its subsidiary and affiliated entities, which offer their products and services under various brand names. these companies engage in a number of businesses, including theme parks and travel, motion pictures and television, publishing, consumer products and interactive services. the walt disney company brands include, among others, the following:
  • abc entertainment
  • abc news
  • adventures by disney
  • aulani, a disney resort & spa
  • bamtech media
  • bindass
  • buena vista catalog company (including disney movie club)
  • d23 | the official disney fan club
  • disney baby
  • disney channels & disneynow
  • disney cruise line
  • disney digital network
  • disney family movies
  • disney movie insiders
  • disney on broadway
  • disney on ice and disney live!
  • disney photopass service
  • disney rewards visa card
  • disney vacation club
  • disney
  • disneyland paris
  • disneyland resort
  • disneylife
  • el capitan theatre
  • espn
  • espn cricinfo
  • espn deportes
  • espn
  • fivethirtyeight
  • freeform
  • fx networks
  • genx entertainment limited
  • hollywood records
  • hungama tv
  • lucasfilm (star wars)
  • marvel
  • marvel shop
  • marvel digital comics
  • muppets
  • pixar animation studios
  • radio disney
  • read riordan
  • shopdisney
  • the undefeated
  • 30 for 30 podcasts
  • united home entertainment private limited
  • utv software communication limited
  • walt disney pictures
  • walt disney studios home entertainment
  • walt disney world resort

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