What can I do about this clause?

{'method': 'WEB_FORM', 'recipient': 'https://corporate.target.com/about/products-services/Target-Privacy-Policy', 'difficulty': 'MODERATE', 'action_type': 'DELETE_DATA', 'instructions': "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.", 'deadline_days': 45, 'deadline_hours': None}

Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'The FTC has jurisdiction over deceptive loyalty program data practices under Section 5 of the FTC Act.', 'complaint_url': 'https://reportfraud.ftc.gov/'}, {'agency': 'State_AG', 'reason': 'State attorneys general in California, Virginia, and Colorado enforce privacy rights related to loyalty program data collection and use.', 'complaint_url': 'https://www.naag.org/find-my-ag/'}

What is the severity of this clause?

ConductAtlas classifies this Target Circle Loyalty Program Data Collection clause as medium severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Target Circle Loyalty Program Data Collection — Target

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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.

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.

Cross-platform context

See how other platforms handle Target Circle Loyalty Program Data Collection and similar clauses.

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Why it matters (compliance & risk perspective)

Target Circle creates a comprehensive cross-channel behavioral profile linking your in-store purchases, online browsing, and offer engagement — this aggregated profile is used for both personalization and advertising targeting.

View original clause language

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.

Institutional analysis (Compliance & legal 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.

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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 →

Provision details

Document information

Document

Target Privacy Policy

Entity

Target

Document last updated

April 29, 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

https://www.target.com/spot/privacy-policy

Wayback Machine

View archived versions →

SHA-256

03ccef46ce3082873d9ba2a43ad976db66be09778b35474f113cb5a73fe11416

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Target | Document: Target Privacy Policy | Record: 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: May 2, 2026

Classification

Severity

Medium

Target Circle Loyalty Program Data Collection