The policy states that Target's digital properties are not directed to children under 13 and that Target does not knowingly collect personal information from children under 13 without parental consent.
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 establishes Target's stated COPPA compliance posture; the 'not knowingly' standard is the operative COPPA threshold, and the absence of a described age verification or parental consent mechanism in the policy text means the practical implementation of this commitment is not detailed in the policy itself.
Interpretive note: The policy states Target does not knowingly collect data from children under 13 but does not describe a specific age verification mechanism, leaving the practical implementation of this commitment uncertain.
This provision establishes that Target's websites and apps are not directed to children under 13 and that Target does not knowingly collect their personal information without parental consent; parents who believe their child's data has been collected may submit a deletion request through Target's privacy portal.
How other platforms handle this
The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
enableGpcSdk: true, gpcSetting: { privacyPolicyLink: '/Privacy-Security-Policy-a-282.html' }
Redfin may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered "public" and will not be subject to the...
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"Our websites and mobile applications are not directed to children under 13. We do not knowingly collect personal information from children under 13 without parental consent.— Excerpt from Target's Target Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly implicates the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which prohibits collection of personal information from children under 13 without verifiable parental consent for operators of websites directed to children or who have actual knowledge of collecting data from children under 13. The FTC has active enforcement history under COPPA and has issued updated rules. California's Age-Appropriate Design Code Act (AADC) and similar state laws may impose additional design and data minimization obligations for platforms accessible to minors. 2. GOVERNANCE EXPOSURE: Medium. Target operates a general-audience retail platform that may be accessed by minors, and the loyalty program and registry products may be used in household contexts where children interact with the platform. The 'not knowingly' standard creates practical compliance risk if data is collected from identifiable minors through household accounts or co-browsing without age verification mechanisms. 3. JURISDICTION FLAGS: Federal COPPA enforcement applies nationwide. California's AADC may impose additional obligations if Target's digital properties are 'likely to be accessed' by children under 18 even if not directed at them. UK GDPR's Children's Code imposes analogous design standards for UK-accessible platforms. 4. CONTRACT AND VENDOR IMPLICATIONS: If analytics or advertising vendors receive data from Target's digital properties and that data may include information about minors, vendor agreements should include COPPA-compliant data handling obligations, prohibitions on behavioral advertising to identified minors, and prompt deletion protocols. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether: age screening or verification mechanisms are implemented at account creation; household account structures that may involve minors are reviewed for COPPA compliance; advertising targeting systems exclude identified minors; and California AADC design requirements are assessed for applicability to Target's digital properties.
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This provision establishes Target's stated COPPA compliance posture; the 'not knowingly' standard is the operative COPPA threshold, and the absence of a described age verification or parental consent mechanism in the policy text means the practical implementation of this commitment is not detailed in the policy itself.
This provision establishes that Target's websites and apps are not directed to children under 13 and that Target does not knowingly collect their personal information without parental consent; parents who believe their child's data has been collected may submit a deletion request through Target's privacy portal.
ConductAtlas has identified this type of provision across 26 platforms. See the full comparison.
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