What CVS Pharmacy does with your data
Pharmacy, beauty, specialty retail and restaurants. People use it through a rewards program, app, or connected service.
Data current as of 2026-09-25; statuses change.
- Program or app
- ExtraCare
- Members
- 90 million accounts (2026). CVS Media Exchange says it has over 90 million addressable ExtraCare members (page accessed 2026-09-25). An Adweek headline cites 74 million loyalty program users (article date not verified). The CVS 10-K does not state a count.
- Retail media
- CVS Media Exchange (CMX). Ad revenue $250 million (2026), analyst-estimate
What it collects and does with your data
- CMX markets ExtraCare data to advertisers: 90M+ addressable members, 77% of CVS sales and 90% of CVS online sales made by ExtraCare members, average membership tenure of 10 years.
- Privacy policy: CVS may sell or share for targeted advertising online and other identifiers, commercial information, internet activity, and non-precise location with business partners and third parties.
- Policy says CVS discloses personal information to research partners, and uses automatic license plate recognition near stores, deleting ALPR data after 60 days unless retention is otherwise necessary.
- Policy lists biometric information among categories of personal information collected.
- The Markup and KFF Health News found trackers on CVS.com telling large social media and advertising platforms which products customers viewed, including at-home HIV tests; CVS said it complied with applicable laws.
Sensitive data
- health/pharmacy
- license plates (ALPR)
- biometric (listed category)
- payment
Enforcement and litigation
3 matters in the research. Where the research says alleged, pending, or settled without admitting wrongdoing, so does this page.
- FTC consent order: FTC charged CVS Caremark failed to take reasonable measures to protect health and financial information after pharmacies discarded prescription records and pill bottles in unsecured trash containers. Settled.
- HHS resolution agreement over the same HIPAA disposal allegations. Amount: $2.25 million.
- Brewer et al. v. CVS Pharmacy and Criteo (Broward County, Fla., No. CACE-26-008094): class alleged website and app trackers sent sensitive data to Criteo and other technology providers (HIPAA Journal names Adobe, Medallia, and Quantum Metric; the settlement agreement lists them, with Braze and Branch Metrics, only among released technology providers). Settlement preliminarily approved with a $20.5M cap covering payments, fees, and costs; claims up to $10 with proof of membership or $5 without; final approval hearing 2026-12-01. Defendants deny that they violated any law. Amount: $20.5 million.
Who else holds your data
Organizations holding a copy of your data, as the research counts them: at least 3. Floor: CVS; Criteo, the co-defendant and the only recipient the Brewer settlement agreement and court-authorized notice name for the alleged disclosure; and at least one research partner (CVS privacy policy). Adobe, Medallia and Quantum Metric are recipients only in HIPAA Journal's summary of the complaint; the settlement agreement names them, with Braze and Branch Metrics, only as released technology providers, so they are not counted. CMX advertiser count not disclosed.
Third parties: 6 disclosed recipient categories. Named: Criteo (alleged recipient named in the Brewer settlement documents). Adobe, Medallia and Quantum Metric per HIPAA Journal's complaint summary; the settlement agreement names them, with Braze and Branch Metrics, only as released technology providers.. Approximate: service providers; business partners and third parties (sale/share); ad networks and measurement services; research partners; government authorities; corporate-transaction parties.
Data brokers linked to CVS Pharmacy
None. The research documents no flow between CVS Pharmacy and a data broker.
Data practices score
11 of 15. Five components, each 0 to 3. How the score works
- Sells or shares
- 2
- Enforcement
- 3
- Retail media scale
- 2
- Sensitive data
- 3
- Opt-out friction
- 1
Estimated emissions for one person
Research gaps
- CMX ad revenue not disclosed; only a low-confidence vendor-blog estimate.
- No CVS-specific email frequency data.
Sources (9)
- https://www.cvsmediaexchange.com/audience accessed 2026-09-25
- https://improvado.io/blog/top-retail-media-networks
- https://www.cvs.com/help/privacy_policy.jsp 2026-07-01
- https://themarkup.org/pixel-hunt/2023/06/30/need-to-get-plan-b-or-an-hiv-test-online-facebook-may-know-about-it 2023-06-30
- https://www.ftc.gov/news-events/news/press-releases/2009/02/cvs-caremark-settles-ftc-chargesfailed-protect-medical-financial-privacy-customers-employeescvs 2009-02-18
- https://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/examples/cvs/index.html 2009-02-18
- https://www.classaction.org/media/cvs-digital-settlement-notice.pdf 2026
- https://www.classaction.org/media/cvs-criteo-settlement-agreement_1.pdf
- https://www.hipaajournal.com/cvs-health-criteo-american-wellness-corp-data-breach-settlements/
The Sources page lists these with their kind and what else uses them.