i can point out where disney explicitly grants you permission to copy PhotoCD and distribute it as long as it's not for commercial purposes.
i have yet to see anywhere where Disney explicitly says you cannot share the product with virtual strangers.
if there is such a thing, I'd love to know. I know of multiple ways to cheat the PhotoPass system and I've made it my intention to not include such information on my photopass site (
http://www.stitchkingdom.com/photopass ), so if Disney says no in official documentation, I'd support that and remove it from my site (which has been visited innumerable times from users at disney.com). otherwise, it's pure conjecture.