Target · Target Terms and Conditions · View original document ↗

Privacy Policy Incorporation by Reference

Medium severity Rare · 3 of 343 platforms
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Recent governance activity Target recorded 40 documented changes in the last 30 days.
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Document Record

What it is

Target's full data collection, sharing, and use practices are governed by a separate Privacy Policy document — by agreeing to the Terms, you also agree to all privacy practices described in that separate document.

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)

Incorporation by reference means users' data handling obligations and rights are governed not only by the standalone Terms and Conditions document but also by the terms stated in Target's Privacy Policy, requiring users to review both documents to understand the complete agreement.

Recent Activity

This document changed recently

Medium Apr 30, 2026

California customers using Target's same-day delivery service will now pay a CA Shipt Shopper Benefit Fee in addition to standard delivery costs, according to the updated terms. The terms do not specify the fee amount, structure, or whether it applies to all same-day orders or only certain product categories. Consumers in California should review their receipt or account details to understand the exact fee amount and whether it was previously being charged but undisclosed, or if this represents a new charge.

View change record →
Medium Apr 16, 2026

Target removed specific language that explained how Target Circle Bonus rewards are earned, calculated, and reflected in customer accounts across different purchase methods (online, in-store, Same Day Delivery, Order Pickup, Drive Up). Previously, the terms clarified that online orders counted as one transaction unless they included Target Plus items or used Same Day Delivery, and specified timing for when bonuses would appear (24 hours for in-store, upon shipment/pickup/delivery for online). Without this clarity, customers must now rely on in-app displays or support channels to understand exactly how their purchases contribute to bonus eligibility, which may create confusion about reward calculation or disputes over earned benefits.

View change record →
Medium Mar 19, 2026

Target's updated Terms and Conditions now include explicit governance for its Target Circle loyalty program and Target Circle 360 membership. The updated terms establish that membership is voluntary and that by joining or continuing to use the program, members agree to Target Circle-specific terms and the Privacy Policy in effect at that time. The terms authorize Target to update the Target Circle Terms, the Target App, or the website at any time without advance notice, with continued program participation constituting acceptance of those updates. You can choose not to join Target Circle or can stop participating in the program to avoid binding yourself to these updated terms.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 27, 2026
First Seen
Apr 27, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Consumer impact (what this means for users)

By accepting Target's Terms, you automatically accept Target's Privacy Policy, which governs how Target collects, uses, and shares your browsing behavior, purchase history, location data, and other personal information — all without requiring a separate explicit consent action.

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.
  • Export Your Data
    Log into your Target account and navigate to the Privacy section to review your data rights, request a copy of your personal data, or submit a do-not-sell request as provided under the CCPA. California residents can also submit requests via Target's CCPA portal.

How other platforms handle this

Shein Medium

enableGpcSdk: true, gpcSetting: { privacyPolicyLink: '/Privacy-Security-Policy-a-282.html' }

Yelp Medium

The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...

Redfin Medium

Redfin may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered "public" and will not be subject to the...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
Your use of the Services is also subject to Target's Privacy Policy, which is incorporated herein by reference.

— Excerpt from Target's Target Terms and Conditions

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY FRAMEWORK: Incorporation by reference of a privacy policy implicates CCPA (Cal. Civ. Code §1798.100 et seq.) notice requirements — specifically the requirement to provide notice at or before the point of personal information collection (Cal. Civ. Code §1798.100(b)). GDPR Art. 13 and Art. 14 require that privacy information be provided in a concise, transparent, intelligible, and easily accessible form — incorporation by reference into a ToS may not satisfy this standard for EU users. FTC Privacy Principles and the FTC Act Section 5 apply to the adequacy and accuracy of the incorporated privacy disclosures. (2)

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC enforces privacy policy accuracy and adequacy under Section 5 of the FTC Act — deviations between stated privacy practices and actual data use are actionable unfair or deceptive acts.
    File a complaint →
  • State AG
    California's AG and the California Privacy Protection Agency enforce CCPA notice and disclosure requirements, including the adequacy of privacy disclosures incorporated by reference into terms of service.
    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 Terms and Conditions
Entity
Target
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
April 27, 2026
Record ID
CA-P-003618
Document ID
CA-D-00259
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
4c6cf8aa3f3ac47d7915d009285bd07d8cf1a1b0a5c192b73df983bfafb7270f
Analysis generated
April 27, 2026 15:09 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Target
Document: Target Terms and Conditions
Record ID: CA-P-003618
Captured: 2026-04-27 15:09:05 UTC
SHA-256: 4c6cf8aa3f3ac47d…
URL: https://conductatlas.com/platform/target/target-terms-and-conditions/privacy-policy-incorporation-by-reference/
Accessed: June 22, 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 Privacy Policy Incorporation by Reference clause do?

Incorporation by reference means users' data handling obligations and rights are governed not only by the standalone Terms and Conditions document but also by the terms stated in Target's Privacy Policy, requiring users to review both documents to understand the complete agreement.

How does this clause affect you?

By accepting Target's Terms, you automatically accept Target's Privacy Policy, which governs how Target collects, uses, and shares your browsing behavior, purchase history, location data, and other personal information — all without requiring a separate explicit consent action.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 3 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.