Why "Data Pass" Sales Land Your Business In Hot Water!

Selling someone a front-end product as the initial merchant and then channeling their billing information to another merchant to be used in conjunction with an up-sale or cross-sale ("back-end sales") is illegal! Under the Restore Online Shopper's Confidence Act (ROSCA), any initial merchant that directly obtains customer billing information cannot disclose this to a third party "post-transaction seller" where it is to be used in the sale of any goods or services by that seller. This practice by the initial merchant is also known as a "data pass."



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