The policy states that Target collects and retains inferences derived from personal information to build consumer profiles reflecting preferences, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities, and aptitudes.
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
Inferences drawn to create consumer profiles are a specifically enumerated category under CCPA/CPRA and analogous state statutes, subject to access rights, deletion rights, and in some contexts correction rights; the breadth of the enumerated inference categories (including psychological trends and aptitudes) extends beyond standard purchase-preference profiling.
This provision establishes that Target builds consumer profiles from inferred data that may encompass psychological trends, predispositions, and aptitudes in addition to purchase and browsing preferences; consumers in covered states have the right to access, correct, and request deletion of these inferred profiles.
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"Inferences drawn from personal information to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.— Excerpt from Target's Target Privacy Policy
1. REGULATORY LANDSCAPE: CCPA/CPRA expressly includes inferences drawn from personal information to create a profile as a category of personal information subject to consumer rights. Colorado CPA, Connecticut CTDPA, and Virginia VCDPA similarly include inferences in their definitions of personal information. The FTC has identified the use of consumer profiling for sensitive inferences (including psychological profiling) as a practice warranting heightened scrutiny. 2. GOVERNANCE EXPOSURE: Medium. The policy's inclusion of psychological trends, predispositions, and aptitudes as inference categories extends beyond standard retail preference profiling. Under CPRA, consumers have the right to access and delete these inferences. The use of such inferences in advertising targeting may require evaluation under CPRA's profiling and automated decision-making provisions, which are subject to ongoing regulatory development. 3. JURISDICTION FLAGS: California creates the highest exposure given CPRA's explicit inclusion of inferences and the CPPA's ongoing rulemaking on automated decision-making and profiling. Colorado's CPA includes opt-out rights for profiling used to make decisions with legal or similarly significant effects. European residents interacting with Target's digital properties may trigger GDPR profiling and automated decision-making provisions. 4. CONTRACT AND VENDOR IMPLICATIONS: If inferences are generated by third-party analytics vendors using consumer data, those vendors must be structured as service providers with data use restrictions. Contracts should prohibit vendors from using inference data for their own profiling or advertising purposes. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether: consumers can access and receive copies of inferred profiles upon request; deletion of inferences is technically implemented across all systems when deletion requests are received; the categories of inferences listed in the policy reflect actual data practices; and the use of psychological and aptitude inferences in advertising targeting is reviewed under evolving CPPA automated decision-making rulemaking.
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Inferences drawn to create consumer profiles are a specifically enumerated category under CCPA/CPRA and analogous state statutes, subject to access rights, deletion rights, and in some contexts correction rights; the breadth of the enumerated inference categories (including psychological trends and aptitudes) extends beyond standard purchase-preference profiling.
This provision establishes that Target builds consumer profiles from inferred data that may encompass psychological trends, predispositions, and aptitudes in addition to purchase and browsing preferences; consumers in covered states have the right to access, correct, and request deletion of these inferred profiles.
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