Disney Settlement Offers a Playbook for CA AG’s Opt-Out Expectations

The California AG expects companies to offer a single mechanism that allows consumers to opt out of all data sales across their services, web domains and devices. That expectation frames the AG’s recent settlement with the Walt Disney Company (Disney), which resolved allegations that Disney violated the CCPA by failing to honor requests by consumers to opt out of the sale or sharing of their data across all of the devices and services linked to their Disney accounts. Disney agreed to pay a record-setting fine, overhaul its opt-out mechanisms and implement ongoing monitoring. This article examines Disney’s alleged violations and the terms of the settlement, along with its implications, and offers compliance lessons from partners at Jones Day, Finnegan, Holland & Knight and Robinson+Cole. See “Challenges in Opt-Out Design and Children’s Privacy Highlighted by Sling TV’s Settlement With California AG” (Nov. 19, 2025).

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