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SHANGHAI DISNEY RESORT PRIVACY POLICY FOR RECRUITMENT

Last Updated: 12/02/2026

This privacy policy applies to job applicants, and describes our collection, use, sharing, transfer, storage and processing of Personal Information (defined more fully below) on the sites and applications where this privacy policy is posted (including shdr.disneycareers.cn site and Shanghai Disney Resort Job Opportunities (上海迪士尼度假区工作, ID “SHDRjob”) WeChat Official Account). This privacy policy does not apply to employee data processed in accordance with an applicable employee privacy notice. If you have been provided with another SHDR privacy notice in connection with your relationship with us, such notice still applies and should be read in conjunction with this privacy policy, which specifically applies to your use of the site or application on which this privacy policy is posted. For the purpose of this privacy policy, “China” refers solely to the mainland of the People’s Republic of China, and does not include Hong Kong, Macao and Taiwan.

TABLE OF CONTENTS

WHO WE ARE

INFORMATION WE COLLECT

USE OF INFORMATION BY SHDR

SHARING, ENTRUSTED PROCESSING OR PUBLIC DISCLOSURE OF PERSONAL INFORMATION

DATA RETENTION

SECURITY

LINKS TO THIRD-PARTY WEBSITES

YOUR STATUTORY RIGHTS AS A DATA SUBJECT

CHANGES TO THIS PRIVACY POLICY

CONTACT US

DEFINITIONS

 

WHO WE ARE

The Personal Information Processor (defined more fully below) with respect to your Personal Information shall be the employer of the position for which you apply, namely, Shanghai International Theme Park Company Limited (上海国际主题乐园有限公司), Shanghai International Theme Park Associated Facilities Company Limited (上海国际主题乐园配套设施有限公司), Shanghai International Theme Park and Resort Management Company Limited (上海国际主题乐园和度假区管理有限公司), as the case may be (collectively, “we” or “us” or “our” or “SHDR”). The Personal Information Processor is responsible for and may use your Personal Information for the purposes described in this privacy policy.

INFORMATION WE COLLECT

We may collect your Personal Information which is relevant to our potential professional relationship with you. The Personal Information we collect may include (any Sensitive Personal Information is highlighted below in bold):

  • basic information, including name, phone number, and email address;
  • professional experience and educational background, including previous work experience (including employer identity, job title, and position), education information (including educational qualifications, degrees, and major), job objective;
  • information about your immediate relative who works in the governmental authority (including name of the relative and the relationship between the relative and you) and information about your referrer who works in the governmental authority (including name, employer, position of the referrer and the relationship between the referrer and you), as necessary for certain positions;
  • information generated during an interview and/or any written assessments (when applicable) in connection with a job application;
  • photos and videos collected by CCTV cameras (when you take an onsite interview, which will only be processed for maintaining public safety or conducting internal or external investigations);
  • if you choose to log in our sites or applications by using your WeChat account, your WeChat OpenID, nickname and profile photo, for completing the login authentication; and
  • other information you provide when you apply for a position, which might include your CV/resume.

We may collect Personal Information directly from you or from entities authorized by you (such as third-party job search platforms, recruitment or headhunting agencies). Please note that if you submit a job application to us through a third-party job search platform, headhunting or job placement agency, the privacy policy of such third party shall apply to your provision of Personal Information to such third party.

USE OF INFORMATION BY SHDR

As noted above, the Personal Information Processor for your information is responsible for and may use your information for the purposes described in this privacy policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, for the following purposes:

  • manage and improve our recruitment and hiring process;
  • manage your job application process, including resume screening, interview(s) and written assessments scheduling;
  • evaluate your job application and make arrangements for your future employment;
  • communicate with you about your account and application and send you information or request feedback about features on our sites and applications;
  • operate and manage our businesses;
  • preserve our economic interests and ensure compliance and reporting (such as complying with our policies and local legal requirements, responding to complaints, and defending litigation); and
  • archiving and record-keeping.

We may analyze your information in aggregate form in the course of our activities and for the same purposes as those listed in this privacy policy. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and current and prospective business partners and to other third parties for other lawful purposes.

We process your Personal Information based on your consent, as necessary for concluding or performing the contract to which you are a party, and/or as necessary for the performance of our statutory duties or legal obligations.

LEGAL REMEDIES AND REGULATORY COMPLIANCE

In addition, we will use your information as permitted by local law to protect our rights, including to:

  • enforce this privacy policy;
  • monitor your use of our sites and applications, and otherwise ensure the privacy and safety of such sites and applications, our property, and that of our affiliates, you or others; and
  • to allow us to pursue available remedies or limit the damages that we may sustain.

Where required, we will use such information to:

  • comply with or evaluate compliance with any applicable law or regulation; and
  • respond to requests from public and governmental authorities, including public and governmental authorities.

CORPORATE TRANSACTIONS

Your Personal Information may be used or transferred by us in the course of a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our businesses, assets, or stock (including in connection with any bankruptcy or similar proceedings).

SHARING, ENTRUSTED PROCESSING OR PUBLIC DISCLOSURE OF INFORMATION

SHARING OF YOUR INFORMATION

We may share Personal Information within The Walt Disney Family of Companies (defined more fully below) for the purposes described in this privacy policy. The obligations which are set out in this privacy policy shall apply to other members of The Walt Disney Family of Companies to the same extent that they apply to the Personal Information Processor of your Personal Information.

We will not share your Personal Information with a third party outside The Walt Disney Family of Companies except in limited circumstances, including:

  • When you direct us to share your Personal Information with another company;
  • When we share your Personal Information with headhunting agencies where necessary;
  • When we share your Personal Information with third parties in connection with the sale of a business, to ensure the safety and security of our guests, employees, and third parties, to protect our rights and property and the rights and property of our guests, employees, and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

Please note that once we share your Personal Information with a third party in some of the above circumstances, the information received by the third party is controlled by that third party and becomes subject to the third party’s privacy practices.

ENTRUSTED PROCESSING OF YOUR INFORMATION

In order to fulfill the aforementioned purposes of use of information, we may entrust our affiliates, service providers or business partners to process your Personal Information (as Entrusted Parties). When such companies perform services on our behalf, like IT service providers, cloud service providers, database providers, consultants, archive storage providers, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law.

PUBLIC DISCLOSURE OF YOUR INFORMATION

We will not publicly disclose your Personal Information without your consent.

DATA RETENTION

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by applicable law, or unless otherwise stated elsewhere in this privacy policy or any other privacy disclosure provided to you.

We will store your Personal Information within the territory of China in accordance with applicable laws and regulations. If we transfer your personal information outside of China, we will strictly comply with the relevant legal requirements. If we have extended an offer to you and you have accepted it, we will, with your consent, transfer certain necessary Personal Information that you provided during the recruitment process to our core human resources systems in order to complete your pre-onboarding process. The details of such transfer will be specified in the SHDR Pre-onboarding Data Protection Notice provided to you by us.

SECURITY

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented appropriate technical, administrative, organizational, and physical security measures that are designed to protect your 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 reasonable efforts, no security measures are perfect or impenetrable.

ONLINE TRACKING TECHNOLOGIES

About Online Tracking Technologies

We and certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you, on our sites and applications using tracking technologies such as browser cookies and software development kits. This tracking data may be used for many purposes including, for example, to:

  • provide useful features to simplify your experience when you use or return to our sites (for example, keeping you logged in);
  • monitor, evaluate, and optimize the use and operation of our sites; and
  • analyze traffic on our sites and on the sites of third parties.

We may collect information whether or not you are logged in or registered, and may associate this tracking data with your registration account (if you have one), in which case we will treat it as Personal Information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.

Types of Online Tracking Technologies

Examples of online tracking technologies include cookies. Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your device warn you each time a cookie is being placed on your device, or you can choose to block all cookies. You do this through your browser settings and/or depending on the website you are visiting, you may also be able to manage your cookies settings via a link in the footer of the website, if applicable. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your user experience more efficient, and some of our services will not function properly.

LINKS TO THIRD-PARTY WEBSITES

Our sites may contain links to other websites. This privacy policy does not address, and we are not responsible for, the privacy, information security, or other practices of any third parties, including any third party operating any website or service to which our sites link. Privacy choices you have made on third party websites or services will not apply to our use of the information we have collected directly through our sites and offline. We encourage you to be aware when you leave our sites and to read the legal notices posted on other sites, including their privacy policies.

YOUR STATUTORY RIGHTS AS A DATA SUBJECT

You may request access to and make a copy of your Personal Information that we collect, correct inaccurate or incomplete Personal Information concerning you, delete your Personal Information in certain circumstances, withdraw your consent previously given to certain types of our processing activities with future effect, transfer your Personal Information we hold to another Personal Information Processor designated by you if the relevant requirements are fulfilled, request an explanation of our rules of processing Personal Information (to the extent that are unclear or not addressed in this privacy policy), where permitted and to the extent required by applicable law.

Please note that if you request to delete your Personal Information or withdraw your consent, we may not be able to continue processing your job application.

We will try to comply with your request as soon as reasonably practicable, within the statutorily required timeline.

Please note that certain Personal Information may be exempt from such access, correction, or suppression rights pursuant to local data protection laws.

CHANGES TO THIS PRIVACY POLICY

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

CONTACT US

If you have questions or requests related to this privacy policy, please feel free to contact us through email at shdr.privacy@disney.com.

You also have the right to lodge any complaint related to data protection with the relevant regulator.

DEFINITIONS

Anonymous Information” is information that does not directly identify, and cannot reasonably be used to directly or indirectly identify, an individual person.

Personal Information Processor” means an organization or individual that, in the course of Personal Information processing activities, independently decides on the processing purposes and methods.

A “Entrusted Party” is a person or entity that processes Personal Information on behalf of a Personal Information Processor (or Personal Information Processors) and that is permitted to perform data processing only as directed by the Personal Information Processor(s).

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 is also treated as Personal Information.

Sensitive Personal Information” means Personal Information that, if leaked or if used illegally, is likely to cause harm to a natural person’s personal dignity or endanger his or her personal safety or the safety of his or her property, including information concerning the person's biometrics, religious beliefs, particular capacity, medical treatments, health, 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” 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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