Provision record
Target · Target Privacy Policy · View original document ↗

Loyalty and Partner Program Data Sharing

Medium severity Medium confidence Explicitdocumentlanguage Common · 294 of 352 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Clause Stability Stable

0
Changes
4
Months Monitored
May 21, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 4545 other provisions on other platforms.

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Close Your Account
    Log into your Target account, navigate to account settings, and select the option to unlink partner accounts (such as Ulta Beauty or Marriott) to stop data sharing with those specific loyalty partners.

How other platforms handle this

Squarespace Medium

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.

Ancestry Medium

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.

Lime Medium

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

See all platforms with this clause type →

Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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 institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • FTC
    The FTC has authority over consumer protection issues related to loyalty program data sharing representations and practices under Section 5 of the FTC Act.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Target Privacy Policy
Entity
Target
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-012848
Document ID
CA-D-00260
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d7515e630a65aad58c9148a9c23310bdb5ac55c05508e24d7e9bb18074d57946
Analysis generated
May 21, 2026 02:11 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Target
Document: Target Privacy Policy
Record ID: CA-P-012848
Captured: 2026-05-21 02:11:48 UTC
SHA-256: d7515e630a65aad5…
URL: https://conductatlas.com/platform/target/target-privacy-policy/provision/CA-P-012848/loyalty-and-partner-program-data-sharing/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Target's Loyalty and Partner Program Data Sharing clause do?

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.

How does this clause affect you?

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 many platforms have this type of clause?

ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.

Is ConductAtlas affiliated with Target?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Target.