Advertising Law - February 2017 #3

by Manatt, Phelps & Phillips, LLP
Contact

Manatt, Phelps & Phillips, LLP

In This Issue:
  • NAD Inquiry Results in Modified Celebrity Endorsements
  • FTC, Volkswagen Work Out Buyback Details
  • Advertisers Push to Repeal FCC Privacy Rule
  • NBA 2K’s Face-Scanning Feature Complies With Law

NAD Inquiry Results in Modified Celebrity Endorsements

As a result of an inquiry by the National Advertising Division, celebrity endorsements of FitTea were revised to better disclose material connections.

The self-regulatory body reviewed advertising for the dietary supplement that featured endorsements on Twitter, Instagram, and other social media from Khloe Kardashian, Kourtney Kardashian, and Kylie Jenner. Each of the celebrities failed to disclose when they were paid to endorse the product and did not disclose in any way their material connection to FitTea, the NAD said.

“When a social media post expresses a personal opinion about how much a poster likes a product or how frequently the poster uses a product, consumers might not understand whether the post is a paid endorsement or the post is spontaneous, without any payment or other compensation being exchanged,” the NAD wrote. “Consumers are likely to weigh an opinion differently if it is a paid endorsement for a product. As a result, such a payment is a connection that is material to consumers and should be disclosed.”

Citing the Federal Trade Commission Guides Concerning the Use of Endorsements and Testimonials for support, the NAD used the agency’s examples for further elaboration. A celebrity discussing a medical procedure in a television interview and a tennis player touting the results of a surgery, mentioning the clinic where it was performed by name, both trigger the requirements of the Guides. In both hypotheticals, consumers might not realize that the celebrity or athlete was paid for sharing the information and because that information might affect the weight given to the endorsement, the relationships should be disclosed, the NAD said.

In response, FitTea informed the NAD that the advertiser’s social media posts were revised to disclose material connections with the endorsers and that, going forward, future advertising will adhere to the FTC’s Guides.

To read the NAD’s press release, click here.

Why it matters: Celebrity endorsements in the social media context will be a hot topic for advertisers in 2017. The FTC made its first significant efforts to enforce the Endorsements and Testimonials Guides last year, most notably in an action against Lord and Taylor. Consumer groups also jumped on the bandwagon, filing multiple complaints with the agency about social media influencers violating the Guides.

FTC, Volkswagen Work Out Buyback Details

Completing the deal between Volkswagen and the Federal Trade Commission over the auto manufacturer’s deceptive claims for emissions standards, the agency announced the details of VW’s buyback program for its 3.0-liter TDI diesel vehicles.

The FTC filed suit against VW last year, alleging that the company’s advertising campaign in support of its “clean diesel” cars was false and deceptive in violation of Section 5 of the Federal Trade Commission Act. The automaker touted the vehicles as low-emission and environmentally friendly despite the presence of “defeat devices” to cheat emissions tests.

In July, VW reached a deal with the FTC (as well as the Department of Justice and the California Attorney General), agreeing to pay $14.7 billion in the largest false advertising settlement in the agency’s history. The partial agreement involved $10 billion in restitution for consumers, efforts VW would make to mitigate environmental harm, and a buyback and lease termination for the company’s 2.0-liter diesel vehicles.

Now the parties have announced another piece of the puzzle–the buyback program for 3.0-liter TDI diesel vehicles. Owners of model years 2009 to 2012 will be able to sell their car back to VW for between $26,000 and $58,000, depending on the model, mileage, and trim. If owners elect to keep their car, they can receive an emissions modification once it is approved by the Environmental Protection Agency and the California Air Resources Board, and will also receive monetary compensation, the Commission said.

VW is expected to obtain regulatory approval for an emissions repair that will bring vehicles into full compliance while not materially reducing the performance of the car, the agency explained. If that approval is received within a set time frame, the lessees and owners of model years 2013-2016 will receive both the emission modification and additional monetary compensation ranging from $8,500 to $17,600. “This means consumers with newer vehicles will receive the car they thought they purchased—plus a substantial additional payment,” the FTC said. If approval is not obtained for the modification, VW will be required to buy back or terminate the lease on those models.

For those owners who sold their TDI vehicles after the defeat device issue became public knowledge, compensation may be available, the agency added, and certain lessees are also eligible for compensation, depending on the make, model year, and availability of approved emissions modifications or repairs.

The buyback program will return more than a billion dollars to consumers, the FTC said, including a contribution from Bosch, the company that manufactured the defeat device. The total amount will depend on future events—for example, if no emissions repair is approved and VW must offer buybacks for the 3.0-liter TDI models, the company may end up paying up to $4 billion. If the modification does receive approval, the amount will likely end up in the $1.25 billion range, the agency predicted.

To read the stipulated orders and other court documents in In re: Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation, click here.

Why it matters: The combination of repairs, additional monetary compensation, and buybacks for certain models will “fully compensate” consumers who purchased 3.0-liter TDI diesel cars from VW, the FTC said. With the most recent order entered in California federal court, the agency completed its case against the auto manufacturer—the largest false advertising settlement in agency history.

Advertisers Push to Repeal FCC Privacy Rule

Advertisers are pushing the Federal Communications Commission to repeal the agency’s privacy rule now that its leadership has changed.

Last November, in a 3-2 vote along party lines, the FCC passed a new privacy rule that requires Internet service providers to obtain opt-in consent before sensitive data (defined to include browsing and app usage history) can be collected and used for ad targeting purposes. Members of the industry immediately spoke out against the rule, arguing that it would have a negative impact on the economy, stifle innovation, make it harder to deliver relevant and useful advertising messages, and cause confusion because the FCC’s broad interpretation of sensitive data is at odds with existing standards.

After the election, a coalition of ad industry groups filed a petition formally requesting that the agency reconsider its order. Following the announcement that Ajit Pai—who voted against the new rule and has repeatedly spoken out against it—would take the lead position at the FCC, the industry joined with other groups to ask that the rule be tossed entirely.

“Consumers have embraced the dynamism of today’s internet, and have come to expect a seamless and consistent online experience for the apps on which they rely, the Web-based sites and services they use, and the devices that deliver those offerings which make our lives easier and more efficient,” the Association of National Advertisers, American Association of Advertising Agencies, American Advertising Federation, Data & Marketing Association, Interactive Advertising Bureau, and Network Advertising Initiative wrote. “Unfortunately, in adopting new broadband privacy rules late last year, the [FCC] took action that jeopardizes the vibrancy and success of the internet and the innovations the internet has and should continue to offer.”

The “onerous and unnecessary” rules “establish a very harmful precedent for the entire internet ecosystem,” that substantially deviates from the Federal Trade Commission’s existing privacy regime, according to the letter. Multiple organizations reflecting members of the cable industry as well as the U.S. Chamber of Commerce joined the missive.

“Amongst other flaws, the FCC [o]rder would create confusion and interfere with the ability of consumers to receive customized services and capabilities they enjoy and be informed of new products and discount offers,” the groups wrote. “Further, the [o]rder would also result in consumers being bombarded with trivial data breach notifications. The FCC [o]rder greatly expands the category of information for which a breach notification would be necessary, even if the consumer is not harmed. The FCC disregards the FTC’s warning about notice fatigue in that consumers who receive too many notices may ignore the important ones.”

While the groups supported the goal of ensuring online privacy and data security protections for consumers, any requirements should “comport with consumer expectations and long-standing privacy policies,” they told the leaders of the U.S. House of Representatives and Senate. But the “FCC’s [o]rder would significantly harm consumers as well as our nation’s digital economy.”

To read the letter requesting repeal of the FCC privacy rule, click here.

Why it matters: Given the new leadership at the FCC as well as the current administration’s willingness to overturn prior decisions, the letter may not be a shot in the dark for the ad industry. Proponents of the rule are not going down without a fight, however, with advocacy groups such as the ACLU and the Center for Digital Democracy authoring their own letter to lawmakers. “The cable, telecom, wireless, and advertising lobbies’ request … is just another industry attempt to overturn rules that empower users and give them a say in how their private information may be used,” the groups wrote. Sen. Al Franken (D-MN) also voiced his support of the rules in a letter to Pai, urging him to “protect freedom of speech by maintaining and enforcing” the order.

NBA 2K’s Face-Scanning Feature Complies With Law

With the growth of digital avatars and face-scanning technology, many tech companies have been hit with suits challenging privacy protections. A new decision from New York federal court may ease their concerns.

Siblings Ricardo and Vanessa Vigil purchased NBA 2K15, in part due to the “My Player” feature that allowed users to undergo a facial scan and create a personalized avatar in the game. Although the Vigils signed a release permitting Take-Two Interactive Software Inc. to take the scan and use the data collected to create an avatar, they alleged the company violated the Illinois Biometric Information Privacy Act (BIPA).

The BIPA sets forth disclosure, consent, and retention requirements for private entities that collect, store, and disseminate biometric data. The Vigils claimed that Take-Two failed to provide adequate disclosures (in particular by failing to inform them that their likenesses would be visible to other players online and not providing a retention schedule or guidelines for destroying biometric identifiers) and therefore their consent was invalid.

The software company moved to dismiss, arguing that the plaintiffs failed to adequately allege concrete harm under the statute as required by Spokeo, Inc. v. Robins. U.S. District Court Judge John G. Koeltl agreed.

Under the BIPA, the collection and storage of biometrics to facilitate financial transactions is not in and of itself undesirable or impermissible, the court said. Instead, the purpose of the statute “is to ensure that, when an individual engages in a biometric-facilitated transaction, the private entity protects the individual’s biometric data, and does not use that data for an improper purpose, especially a purpose not contemplated by the underlying transaction.”

Take-Two’s personalized basketball avatar feature complied with the statutory requirements, the court said.

“The plaintiffs … allege that the MyPlayer feature functioned exactly as anticipated,” the judge wrote. “There is no allegation that Take-Two has disseminated or sold the plaintiffs’ biometric data to [third parties] or that Take-Two has used the plaintiffs’ biometric information in any way not contemplated by the only possible use of the MyPlayer feature: the creation of personalized basketball avatars for in-game play.”

The Vigils further failed to establish an imminent risk of harm that their biometrics could actually be misused and no event (such as data theft) has occurred that could demonstrate the risk was a reality, the court said. While the plaintiffs told the court that the potential risk of harm associated with their face scans could be potentially great, “the hypothetical magnitude of a highly speculative and abstract injury that is certainly not impending does not make the injury any less speculative and abstract,” the court said.

None of the purported statutory violations were sufficient to establish standing or actual harm, Judge Koeltl concluded, rejecting the plaintiffs’ other theories of additional harm including invasion of privacy and reluctance to enter into future biometric-facilitated transactions. The Vigils agreed to have their faces scanned and displayed on personalized basketball avatars and standing could not be manufactured based on fears of hypothetical future harm, the court said.

“The plaintiffs cannot aggregate multiple bare procedural violations to create standing where no injury-in-fact otherwise exists,” the judge wrote, dismissing the complaint with prejudice. “Accordingly, the plaintiffs do not have Article III standing to pursue their claims against Take-Two.”

To read the opinion and order in Vigil v. Take-Two Interactive Software, Inc., click here.

Why it matters: As the use of biometric scanning continues to increase, so will the number of consumer challenges to companies making use of the technology. In addition to Take-Two (whose legal woes are not over, as the plaintiffs have already filed an appeal), both Facebook and Google have already been hit with putative class actions asserting violations of the Illinois BIPA.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Manatt, Phelps & Phillips, LLP | Attorney Advertising

Written by:

Manatt, Phelps & Phillips, LLP
Contact
more
less

Manatt, Phelps & Phillips, LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.