Privacy & Cybersecurity Law Blog

On February 11, 2026, California Attorney General Rob Bonta announced a settlement with the Walt Disney Company (“Disney”) to resolve allegations that Disney did not sufficiently comply with consumer opt-out rights under the California Consumer Privacy Act (“CCPA”) and, in doing so, also violated California’s Unfair Competition Law. The proposed settlement will require Disney to pay a record $2.75 million fine and fully comply with the CCPA’s opt-out of sale and sharing rights.

The settlement emerged from a California Department of Justice Investigative Sweep announced in January 2024 targeting streaming services’ compliance with the CCPA. The CCPA provides California consumers with robust opt-out of sale and sharing (for cross-context behavioral advertising) rights. The CCPA requires businesses to (1) provide simple and easy-to-use opt-out request methods that reflect the manner in which the business primarily interacts with the consumer, and (2) effectuate such requests with respect to all of the consumer’s personal information maintained by the business.

According to the complaint, Disney failed to honor consumer opt-out requests across all of its streaming services, apps and online services, as required by the CCPA. Disney owns and operates streaming services Disney+, ESPN+ and Hulu, generating revenue through subscription fees and advertising. Consumers can access these streaming services through their phones, tablets, computers and TVs.

Through the Investigative Sweep, Attorney General Bonta’s Office discovered that Disney failed to honor consumer opt-out requests across all of Disney’s streaming services, apps and online services and did not adequately communicate such requests to its third-party advertising partners. The complaint alleged that consumers had to manually submit opt-out requests on each Disney online service and through each device to fully effectuate their opt-out requests, in violation of the CCPA’s requirement that opt-out requests be frictionless, simple, and comprehensive. Additionally, consumers allegedly did not have the ability to opt out of the sale or sharing of their personal information through Disney’s TV streaming apps. Rather, consumers were redirected from the relevant Disney TV streaming app to a website to complete their opt-out request. Attorney General Bonta alleged that Disney’s failure to fully effectuate opt-out requests across all of Disney’s properties deceived consumers and resulted in a fraudulent act or practice under California’s Unfair Competition Law.

In announcing the settlement, Attorney General Bonta stated, “Consumers shouldn’t have to go to infinity and beyond to assert their privacy rights . . . A consumer’s opt-out right applies wherever and however a business sells data — businesses can’t force people to go device-by-device or service-by-service.”