If you have location services enabled on your phone, Target may collect your precise real-time location through the Target app to show you nearby stores, check inventory, and serve location-based ads.
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
Precise geolocation data is classified as sensitive personal information under several state privacy laws and can reveal sensitive details about your daily movements, routines, and personal activities beyond what is necessary for core retail functions.
Allowing the Target app to access your precise location means Target may track your real-time physical movements and use that data for advertising purposes in addition to store-finding features. Under CPRA and similar state laws, precise geolocation is classified as sensitive personal information with enhanced opt-out or opt-in rights.
How other platforms handle this
Geolocation Information, if you have consented by enabling location access, we may receive and store your precise location information, including when our apps are running in the foreground (our app is open and on screen) or background (our app is open, not on screen) of your device. You may use our...
We may collect the precise geographic location of your device when you use our services. We collect this information with your consent where required by law. You can withdraw your consent at any time by adjusting your device settings to disable location sharing.
We may collect information about your location, including precise geolocation information, when you use our Services. We use this information to provide location-based services, such as showing you products available in your area, and for other purposes described in this Privacy Policy.
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"Precise geolocation: We may collect your precise, real-time location when you use our app and have enabled location services on your device. We use this information to provide you with relevant information such as nearby store locations and product availability, to improve our services, and to serve you relevant advertising.— Excerpt from Target's Target Privacy Policy
1. REGULATORY LANDSCAPE: Precise geolocation is classified as sensitive personal information under the CPRA, requiring businesses to offer consumers the right to limit its use and disclosure. The California Privacy Protection Agency enforces this requirement. The Washington My Health MY Data Act treats geolocation data associated with health-related activities as consumer health data subject to consent requirements. The FTC has issued guidance and enforcement actions regarding deceptive geolocation data practices. 2. GOVERNANCE EXPOSURE: Medium to High. The use of precise geolocation for advertising purposes, as opposed to purely operational uses such as store location, is a use case that regulators have scrutinized. The policy discloses this practice, which mitigates deception risk, but the adequacy of the opt-out mechanism for this sensitive data category requires verification under CPRA's limit-use right. 3. JURISDICTION FLAGS: California requires a clear mechanism for consumers to limit the use of sensitive personal information including precise geolocation. Washington's My Health MY Data Act may apply if geolocation data is used in connection with health-related retail categories such as pharmacy or wellness products. Illinois and other states with emerging comprehensive privacy laws may create additional obligations as those frameworks take effect. 4. CONTRACT AND VENDOR IMPLICATIONS: Any third-party analytics or advertising vendors receiving precise geolocation data should be assessed as processors or service providers under applicable state law. Data processing agreements should restrict geolocation data use to disclosed purposes and prohibit secondary sale or use. 5. COMPLIANCE CONSIDERATIONS: The compliance team should confirm that the app-level permission request for location access is accompanied by a clear explanation of all uses including advertising, and that device-level permission alone is not treated as sufficient consent for all downstream data uses. The limit-use mechanism for sensitive personal information under CPRA should specifically encompass precise geolocation used for advertising.
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Precise geolocation data is classified as sensitive personal information under several state privacy laws and can reveal sensitive details about your daily movements, routines, and personal activities beyond what is necessary for core retail functions.
Allowing the Target app to access your precise location means Target may track your real-time physical movements and use that data for advertising purposes in addition to store-finding features. Under CPRA and similar state laws, precise geolocation is classified as sensitive personal information with enhanced opt-out or opt-in rights.
ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.
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