Online retailers often learn information about a consumer that may be used  to  help identify other products, services, or companies that may be of interest.  For example, if a consumer purchases an airplane ticket to Washington DC, the consumer may want information about hotels that they might use, popular restaurants that they might visit, or amenities at the airport.

Although online retailers often strive to provide recommendations quickly, and to make a consumer’s transition to a third party retailer seamless, the Restore Online Shoppers’ Confidence Act (“ROSCA”) generally prohibits one online merchant from transferring payment information (e.g., a credit card number) to a second online merchant.

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Questions to consider when evaluating the data privacy issues involved in passing information between online retailers:

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