Target · Target Terms and Conditions · View original document ↗

User-Generated Content License

Medium severity Medium confidence Explicitdocumentlanguage Rare · 7 of 343 platforms
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Recent governance activity Target recorded 66 documented changes in the last 30 days.
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Document Record

What it is

Users who submit any content to Target, including reviews, photos, and comments, grant Target and its affiliates a perpetual, irrevocable, royalty-free, sublicensable license to use, reproduce, modify, distribute, and display that content worldwide in any media.

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 that any content submitted through Target's platform is subject to a broad license that is perpetual and irrevocable, meaning the license cannot be withdrawn after submission. The sublicensable nature of the license permits Target to extend these rights to affiliated entities and third parties.

Interpretive note: The interaction between the irrevocable license grant and GDPR right-to-erasure obligations for EU-connected users creates interpretive uncertainty regarding the practical enforceability of the perpetual license in those jurisdictions.

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.

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Clause Stability Stable

0
Changes
3
Months Monitored
Apr 27, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 646 other provisions on other platforms.

Consumer impact (what this means for users)

Under this clause, any review, photo, or other content submitted by a user to Target becomes subject to a license that permits Target and its affiliates to use, modify, reproduce, and distribute that content globally in perpetuity and without compensation. The irrevocable nature of the license means the user cannot withdraw permission after submission.

How other platforms handle this

Epic Games Medium

By submitting, sharing, or otherwise making User-Generated Content available through any of the Licensed Products, including by submitting User-Generated Content using UEFN, you grant Epic a royalty-free, perpetual, irrevocable, non-exclusive, sublicensable, worldwide license to use, reproduce, modi...

Steam Medium

As a Subscriber you may submit or transmit (collectively, "post") Content on or through Steam, including but not limited to, written works, images, photos, messages, comments, game data, gameplay recordings, and profile data ('User Generated Content' or 'UGC'). By posting any UGC on Steam, you expre...

Nintendo Medium

By submitting or posting any content on or through the Sites, you grant Nintendo a perpetual, irrevocable, worldwide, royalty-free, non-exclusive license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform and display such content (in whole or part...

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▸ View Original Clause Language DOCUMENT RECORD
"
By submitting content to Target, you grant Target and its affiliates a non-exclusive, royalty-free, perpetual, irrevocable, and fully sublicensable right to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, and display such content throughout the world in any media.

— Excerpt from Target's Target Terms and Conditions

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision implicates FTC guidance on endorsements and testimonials, which requires that user reviews used in advertising contexts reflect genuine consumer experiences and that any material connections be disclosed. EU data protection law under the GDPR may interact with the perpetual license grant where the submitted content constitutes personal data, as data subjects retain rights to erasure that may conflict with an irrevocable license assertion. (2) GOVERNANCE EXPOSURE: Medium. The breadth of the license, including the right to create derivative works and sublicense, is operationally significant for any content that may be used in advertising, marketing, or third-party distribution contexts. The irrevocable framing may face scrutiny under GDPR erasure rights for EU-connected users. (3) JURISDICTION FLAGS: EU and EEA users retain rights to erasure of personal data under GDPR, which may limit the practical enforceability of an irrevocable content license where the content constitutes or contains personal data. California residents may have additional rights regarding commercial use of their likeness under California Civil Code Section 3344 if submitted content includes images. (4) CONTRACT AND VENDOR IMPLICATIONS: The sublicensable nature of the license means content may be distributed to affiliates and third-party partners without additional user consent; procurement and vendor teams should assess whether downstream use of user content by sub-licensees is governed by adequate contractual controls. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the scope of this license is disclosed with sufficient clarity at the point of content submission to satisfy notice requirements under applicable consumer protection and data protection law. Review whether content moderation and deletion workflows are consistent with the irrevocable license language, particularly for EU users exercising erasure rights.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over the use of consumer reviews and user-generated content in advertising and marketing contexts under its endorsement and testimonial guidelines
    File a complaint →

Provision details

Document information
Document
Target Terms and Conditions
Entity
Target
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-003613
Document ID
CA-D-00259
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
480b5d4a311d08d87b75f1a22d1c751d68d0d186ac76aff1c64d8689245b2360
Analysis generated
May 21, 2026 04:50 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Target
Document: Target Terms and Conditions
Record ID: CA-P-003613
Captured: 2026-05-21 04:50:01 UTC
SHA-256: 480b5d4a311d08d8…
URL: https://conductatlas.com/platform/target/target-terms-and-conditions/user-generated-content-license/
Accessed: July 4, 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 User-Generated Content License clause do?

This provision establishes that any content submitted through Target's platform is subject to a broad license that is perpetual and irrevocable, meaning the license cannot be withdrawn after submission. The sublicensable nature of the license permits Target to extend these rights to affiliated entities and third parties.

How does this clause affect you?

Under this clause, any review, photo, or other content submitted by a user to Target becomes subject to a license that permits Target and its affiliates to use, modify, reproduce, and distribute that content globally in perpetuity and without compensation. The irrevocable nature of the license means the user cannot withdraw permission after submission.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 7 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.