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
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
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.
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
"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
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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 288 platforms. See the full comparison.
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