Target · Target Privacy Policy · View original document ↗

Target Circle Loyalty Program Data Collection

Medium severity Unique · 0 of 343 platforms
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Recent governance activity Target recorded 28 documented changes in the last 30 days.
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Document Record

What it is

When you use Target Circle, Target tracks your purchases, offer interactions, and overall shopping activity, and combines that data with information from all your other Target interactions to build a detailed profile about you.

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)

The clause establishes Target's data collection scope and aggregation practices within the loyalty program framework. The authorization to combine loyalty data with multi-channel data sources creates an integrated customer profile that informs personalization and offer delivery mechanisms.

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 27, 2026
First Seen
Apr 27, 2026
Last Seen
This clause type exists across 967 other provisions on other platforms.

Consumer impact (what this means for users)

Participation in Target Circle means your entire shopping history across stores, website, and app is aggregated into a single profile that Target uses for targeted marketing and may share with advertising partners — opting out of Target Circle data use may limit personalization but also reduces advertising profile scope.

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.
  • Delete Your Data
    Within 45 days
    Navigate to Target's privacy request page, select 'Delete My Personal Information,' and submit the form with your account details. Target is required to respond within 45 days under CCPA.

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▸ View Original Clause Language DOCUMENT RECORD
"
When you participate in Target Circle, we collect information about your purchases, interactions with offers, and other activity to personalize your experience and provide you with relevant offers and recommendations. We may combine this information with other data we collect about you from our stores, website, and mobile app.

— Excerpt from Target's Target Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY FRAMEWORK: Loyalty program data collection implicates CCPA/CPRA §1798.100 (right to know what personal information is collected), §1798.105 (right to delete), and §1798.120 (right to opt out of sharing). The FTC Act Section 5 applies to any deceptive representations about how loyalty data is used. State equivalents in Virginia (VCDPA), Colorado (CPA), and Illinois apply.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has jurisdiction over deceptive loyalty program data practices under Section 5 of the FTC Act.
    File a complaint →
  • State AG
    State attorneys general in California, Virginia, and Colorado enforce privacy rights related to loyalty program data collection and use.
    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
TCPA
United States Federal
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
April 27, 2026
Last verified
April 27, 2026
Record ID
CA-P-003620
Document ID
CA-D-00260
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
03ccef46ce3082873d9ba2a43ad976db66be09778b35474f113cb5a73fe11416
Analysis generated
April 27, 2026 15:13 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Target
Document: Target Privacy Policy
Record ID: CA-P-003620
Captured: 2026-04-27 15:13:37 UTC
SHA-256: 03ccef46ce308287…
URL: https://conductatlas.com/platform/target/target-privacy-policy/target-circle-loyalty-program-data-collection/
Accessed: June 18, 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 Data Collection clause do?

The clause establishes Target's data collection scope and aggregation practices within the loyalty program framework. The authorization to combine loyalty data with multi-channel data sources creates an integrated customer profile that informs personalization and offer delivery mechanisms.

How does this clause affect you?

Participation in Target Circle means your entire shopping history across stores, website, and app is aggregated into a single profile that Target uses for targeted marketing and may share with advertising partners — opting out of Target Circle data use may limit personalization but also reduces advertising profile scope.

Is ConductAtlas affiliated with Target?

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