Target · Target Terms and Conditions · View original document ↗

User-Generated Content License

Medium severity Rare · 7 of 325 platforms
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Recent governance activity Target recorded 9 documented changes in the last 30 days.
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Document Record

What it is

When you post a review, photo, or comment on Target's website or app, you give Target the permanent, free right to use that content however it wants — including in advertising — anywhere in the world.

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 provision establishes Target's operational right to incorporate user content into its business operations without ongoing compensation or time limitations. The sublicensability provision enables Target to extend these usage rights to partner entities, expanding the scope of authorized content reuse across its commercial ecosystem.

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 →

Consumer impact (what this means for users)

Any photo, review, or comment you post on Target's platform can be used by Target commercially, forever, in any format globally, without paying you or asking for further permission — this is broader than what most consumers expect when writing a product review.

How other platforms handle this

Waze Medium

By submitting content to Waze, including map edits, reports, comments, or other contributions, you grant Waze a worldwide, royalty-free, perpetual, irrevocable, non-exclusive license to use, reproduce, modify, adapt, publish, translate, distribute, and display such content in any form, media, or tec...

Booking.com Medium

By uploading photos/images to our Platform, you hereby grant to Booking.com a non-exclusive, worldwide, royalty-free, irrevocable, transferable license to use, reproduce, display, distribute, prepare derivative works of and/or translate such photos/images, in any format (digital, print, etc.) and fo...

Hugging Face Medium

You hereby grant us a worldwide, royalty-free and non-exclusive license to use, display, publish, reproduce, distribute, and make derivative works of such Content to provide Services and as otherwise permitted under these Terms and our Privacy Policy.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
By posting or submitting any content on or through the Services, you grant Target a non-exclusive, royalty-free, perpetual, irrevocable, and fully sublicensable right to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform 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 FRAMEWORK: The UGC license implicates the Copyright Act (17 U.S.C. §101 et seq.) — specifically the right of reproduction (§106(1)), derivative works (§106(2)), and public display (§106(5)). FTC Act Section 5 and FTC Endorsement Guides (16 C.F.R. Part 255) apply if user content is used in advertising without adequate disclosure. California's right of publicity statute (Cal. Civ. Code §3344) may apply if user-submitted photos are used commercially without consent beyond the ToS. CCPA (Cal. Civ. Code §1798.140) definitions of personal information may encompass UGC content containing personal data. (2)

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC Endorsement Guides and FTC Act Section 5 apply when consumer-submitted content is used in advertising without adequate disclosure of the commercial relationship.
    File a complaint →

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-003613
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-003613
Captured: 2026-04-27 15:09:05 UTC
SHA-256: 4c6cf8aa3f3ac47d…
URL: https://conductatlas.com/platform/target/target-terms-and-conditions/user-generated-content-license/
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 User-Generated Content License clause do?

The provision establishes Target's operational right to incorporate user content into its business operations without ongoing compensation or time limitations. The sublicensability provision enables Target to extend these usage rights to partner entities, expanding the scope of authorized content reuse across its commercial ecosystem.

How does this clause affect you?

Any photo, review, or comment you post on Target's platform can be used by Target commercially, forever, in any format globally, without paying you or asking for further permission — this is broader than what most consumers expect when writing a product review.

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.