Catalog sales are defined as any offer for sale or any solicitation for an order for a consumer product with a written warranty, which includes instructions for ordering the product which do not require a personal visit to the seller's establishment. On-line vendors using an electronic catalog to sell goods should fall within this definition. Commerce on the Web can actually facilitate compliance with consumer disclosure requirements and local language requirements through links and multi-language versions of terms of use. Disclosures in the local language can be as close to a consumer as a click on an icon. The U.S. Federal Trade Commission's charges against Geocities and resulting settlement require that careful attention be given to both the design of information practices as well as compliance with the practices stated in a privacy policy.
Deeds have to match words.
Privacy policy certifiers have also adopted stronger review processes prior to granting certification to a Web site's policy. Once a privacy policy is adopted and certified, it cannot be unilaterally changed and still retain certification. Protection of information about children was of special concern and that was the initial target of federal legislation late in 1998. The regulations will be effective April 21, 2000. Web sites of all types will need to consider a privacy policy since more of such sites collect some kind of personal information about visitors.