The policy states that Target collects biometric information, specifically face geometry scans, when consumers use the virtual beauty try-on feature on Target's digital platforms.
This analysis describes what Target's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision requires compliance with state biometric privacy statutes including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and Washington's biometric privacy law, each of which imposes specific written consent, retention schedule, and destruction obligations prior to and following collection of biometric identifiers.
Interpretive note: The policy discloses biometric collection but does not detail the specific consent mechanism, retention schedule, or destruction protocol, making it unclear whether the collection practice as implemented satisfies applicable state biometric statutes.
This provision establishes that consumers who use Target's virtual try-on feature provide biometric face geometry data to Target; the policy discloses this collection but the consent mechanism and retention/destruction commitments applicable to this data category are not fully detailed in the policy text itself.
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"Biometric information, such as a face geometry scan when you use our virtual try-on feature.Excerpt from Target's Privacy Policy
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This provision requires compliance with state biometric privacy statutes including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and Washington's biometric privacy law, each of which imposes specific written consent, retention schedule, and destruction obligations prior to and following collection of biometric identifiers.
This provision establishes that consumers who use Target's virtual try-on feature provide biometric face geometry data to Target; the policy discloses this collection but the consent mechanism and retention/destruction commitments applicable to this data category are not fully detailed in the policy text itself.
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