Target · Target Privacy Policy · View original document ↗

Target Circle Loyalty Program Behavioral Profiling

Medium severity Unique · 0 of 325 platforms
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Recent governance activity Target recorded 9 documented changes in the last 30 days.
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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 the operational basis for the Target Circle program's personalization functionality and creates a direct linkage between data collection and incentive delivery. It also establishes that certain processing activities under Target Circle are subject to user opt-out rights, creating a conditional consent model for specified purposes.

Consumer impact (what this means for users)

Users who participate in Target Circle authorize Target to collect and process specified personal information categories for targeted offer delivery and member identification. The terms establish opt-out mechanisms for certain processing purposes, meaning users may modify data usage for specific Target Circle functions rather than opt out entirely.

How other platforms handle this

Microsoft Medium

Microsoft uses the data we collect to provide you with rich, interactive experiences. In particular, we use data to: provide and improve our products; personalize your experiences; make recommendations and display advertising. For advertising, we use data collected through our advertising services i...

Pinterest Medium

We infer information about you based on how you use Pinterest. For example, if you engage with Pins about travel, we may infer you are interested in travel. We use this information to provide more relevant recommendations and advertising. We may combine the information we collect about you with info...

Riot Games Medium

We and our third-party partners, including advertising partners, may use the information we collect from you, including information about your gameplay, preferences, and device, to provide you with targeted advertising both within and outside of our Services. We may share data with advertising partn...

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▸ View Original Clause Language DOCUMENT RECORD
"
In order to provide you with the incentives described above, we use personal information about you including your name, phone number, email address, purchase history, birthdate, etc. to identify you as a member of the program and provide you with relevant messaging, experiences and deals. These financial incentives are reasonably related to the value of the data you provide. In connection with Target Circle, we may process your personal information for certain purposes for which you have opt out rights.

— Excerpt from Target's Target Privacy Policy

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
TCPA
United States Federal

Provision details

Document information
Document
Target Privacy Policy
Entity
Target
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-001374
Document ID
CA-D-00260
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2ada96ab96828e67aca9fbda0574b799477f7b5740302a307f04ec582983a272
Analysis generated
May 10, 2026 13:05 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Target
Document: Target Privacy Policy
Record ID: CA-P-001374
Captured: 2026-05-10 13:05:34 UTC
SHA-256: 2ada96ab96828e67…
URL: https://conductatlas.com/platform/target/target-privacy-policy/target-circle-loyalty-program-behavioral-profiling/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Target's Target Circle Loyalty Program Behavioral Profiling clause do?

This provision establishes the operational basis for the Target Circle program's personalization functionality and creates a direct linkage between data collection and incentive delivery. It also establishes that certain processing activities under Target Circle are subject to user opt-out rights, creating a conditional consent model for specified purposes.

How does this clause affect you?

Users who participate in Target Circle authorize Target to collect and process specified personal information categories for targeted offer delivery and member identification. The terms establish opt-out mechanisms for certain processing purposes, meaning users may modify data usage for specific Target Circle functions rather than opt out entirely.

Is ConductAtlas affiliated with Target?

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