Under ROSCA, it is now illegal for initial merchants to collect and pass billing information directly to a third-party seller (a "data-pass"). If you are a "post-transaction seller", you need to now obtain informed consent from any customers passed on by initial merchants before you can obtain their billing information. You also must clearly and conspicuously disclose the material terms of the transaction before obtaining customer billing information. Post-transaction sellers have the option to generate a ROSCA Informed Consent when building either website terms of service or a digital product license using our online service.