The policy states that Target shares personal information with loyalty and partner program companies, including Ulta Beauty and Marriott, in connection with program participation.
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 that Target Circle program participation results in personal information sharing with named third-party loyalty partners whose own data practices are governed by their independent privacy policies rather than Target's, creating data flows that consumers should evaluate in the context of multi-brand loyalty ecosystems.
Interpretive note: The policy names specific partners but does not specify the categories of data shared or the contractual restrictions imposed on partner data use, creating uncertainty about whether this sharing constitutes a 'sale' under applicable state statutes.
This provision establishes that participation in Target's loyalty program may result in personal information being shared with named partner companies including Ulta Beauty and Marriott; consumers can manage partner account links through their Target account profile settings.
How other platforms handle this
We may share your personal information with third parties in the following circumstances: with service providers who perform services on our behalf; with business partners with whom we jointly offer products or services; in connection with, or during negotiations of, any merger, sale of company asse...
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
Monitoring
Target has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.
"Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.— Excerpt from Target's Target Privacy Policy
1. REGULATORY LANDSCAPE: CCPA/CPRA requires disclosure of categories of third parties receiving personal information and the purposes of sharing. Where loyalty partner data sharing constitutes a 'sale' or 'sharing' for advertising or cross-context behavioral advertising purposes, opt-out rights apply. The FTC Act governs representations about loyalty program data practices. Individual partner companies are independently subject to applicable privacy law. 2. GOVERNANCE EXPOSURE: Medium. Named partner disclosure (Ulta Beauty, Marriott) provides transparency but does not specify the categories of data shared, the purposes for which partners may use the data, or whether partners are contractually restricted from using shared data for independent marketing purposes. If partners use shared data for their own advertising, the sharing may constitute a 'sale' under CPRA absent a qualifying service provider structure. 3. JURISDICTION FLAGS: California creates the most immediate exposure for multi-party loyalty data sharing under CPRA. The Illinois consumer fraud statute may apply if program terms do not adequately disclose the scope of data sharing. Texas TDPSA imposes similar disclosure obligations. 4. CONTRACT AND VENDOR IMPLICATIONS: Data sharing agreements with Ulta Beauty and Marriott should specify permitted data uses, prohibition on onward sale, and deletion obligations. If these partners use received data for their own marketing, contracts should reflect third-party rather than service provider status, and Target's privacy disclosures should reflect this distinction. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether: the categories of data shared with loyalty partners are specifically identified in the policy or in a linked disclosure; partner agreements include data use restrictions; consumers who opt out of sale or sharing have that opt-out applied to loyalty partner data flows; and account unlinking mechanisms (referenced in Target's account settings) result in prompt data deletion by the partner.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 10 platforms + same-day alerts. No credit card required.
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision establishes that Target Circle program participation results in personal information sharing with named third-party loyalty partners whose own data practices are governed by their independent privacy policies rather than Target's, creating data flows that consumers should evaluate in the context of multi-brand loyalty ecosystems.
This provision establishes that participation in Target's loyalty program may result in personal information being shared with named partner companies including Ulta Beauty and Marriott; consumers can manage partner account links through their Target account profile settings.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Target.