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The policy states that when consumers purchase from third-party sellers on the Target Plus marketplace, Target shares the consumer's name, address, and items purchased with those sellers as needed to fulfill the order.
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 Plus marketplace transactions involve personal information disclosure to third-party sellers who are not directly subject to Target's privacy policy, creating a data flow that consumers may not associate with a Target-branded transaction and that may require evaluation under applicable data sharing and service provider frameworks.
This provision establishes that purchases from third-party sellers on the Target Plus marketplace result in sharing of the consumer's name, shipping address, and order details with those sellers; the privacy practices of individual Target Plus sellers are governed by their own policies rather than Target's.
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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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"Target Plus partners. If you purchase from a Target Plus partner, we share your personal information needed to complete your order, such as your name, address, and items purchased.Excerpt from Target's Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages CCPA/CPRA data sharing disclosure requirements, which require businesses to identify categories of third parties with whom personal information is shared and the purposes of sharing. The FTC Act applies to deceptive representations about the scope of data sharing in marketplace contexts. State consumer protection statutes in California, Texas, and Colorado may impose additional disclosure obligations regarding marketplace seller data access. 2. GOVERNANCE EXPOSURE: Medium. The disclosure is present in the policy but consumers may not readily understand that completing a Target Plus purchase results in personal information transfer to a third-party seller outside Target's direct contractual control. If Target Plus sellers receive data beyond what is necessary for fulfillment, the transaction may constitute a 'sale' or 'sharing' under CPRA depending on the contractual relationship between Target and the seller. 3. JURISDICTION FLAGS: California creates the most defined exposure; CPRA requires disclosure of the purposes for sharing and whether sellers are structured as service providers, contractors, or third parties. If Target Plus sellers are third parties rather than service providers, consumers' opt-out rights may apply to this data flow. Illinois and other states with consumer fraud statutes may require adequate disclosure of marketplace data sharing. 4. CONTRACT AND VENDOR IMPLICATIONS: Procurement and legal teams should evaluate whether Target Plus seller agreements include: data use limitations restricting sellers to order fulfillment purposes; prohibition on onward sale or sharing of consumer data received from Target; deletion obligations upon order completion; and compliance representations regarding applicable privacy laws in the seller's jurisdiction. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether Target Plus sellers are classified as service providers or third parties under CPRA; whether data minimization principles are applied to limit the information shared to what is strictly necessary for fulfillment; whether consumers can exercise deletion rights as to data held by Target Plus sellers; and whether the policy disclosure is sufficiently specific to satisfy CPRA's disclosure requirements for categories of third parties.
Regulatory citations, enforcement risk, and due diligence action items.
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This provision establishes that Target Plus marketplace transactions involve personal information disclosure to third-party sellers who are not directly subject to Target's privacy policy, creating a data flow that consumers may not associate with a Target-branded transaction and that may require evaluation under applicable data sharing and service provider frameworks.
This provision establishes that purchases from third-party sellers on the Target Plus marketplace result in sharing of the consumer's name, shipping address, and order details with those sellers; the privacy practices of individual Target Plus sellers are governed by their own policies rather than Target's.
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
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