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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.
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we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
Any such de-identified genetic information and phenotypic information we share with third parties for research purposes is done in accordance with Part 46 (beginning with Section 46.101) of Title 45 of the Code of Federal Regulations.
if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services
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"Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.Excerpt from Target's 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.
Regulatory citations, enforcement risk, and due diligence action items.
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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.
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Target.