Best Practices: Online Subscription Upselling

CDT is releasing the final version of its best practices for online subscription upselling to give guidance to companies that advertise to consumers engaged in the checkout process for unrelated goods or services.

The best practices document represents the culmination of months of work by members of CDT’s Internet Privacy Working Group. The guidelines are divided into three sections:

  1. How to provide clear notice to consumers about different products;
  2. Prohibiting the transfer of consumer financial information to third-party vendors;
  3. Providing for redress rights for consumers who felt they had been unfairly charged.


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