Alert: European Commission Extends Digital Single Market Strategy with Further Consultations

Cooley LLP
Contact

Introduction

The European Commission's Digital Single Market (DSM) strategy is a wide-ranging initiative aimed at creating better access for consumers and businesses to digital services across Europe (for more details see this Cooley alert). Indicating the frustration felt within the Commission at the barriers imposed by a patchwork of often divergent national laws that persist across the EU's 28 Member States, it has promised "tearing down regulatory walls and moving from 28 national markets to a single one", leading to annual benefits of up to €415 billion for the EU economy.

Nevertheless, press reports on the launch of the DSM strategy earlier this year were accompanied by rather lurid headlines, variously claiming that Europe "hates Silicon Valley", "hates American tech companies" and "hates US Internet giants". Although Commissioners have taken steps to dispel such concerns, including by personally visiting Silicon Valley in recent weeks, the possibility of intervention in markets to create a more 'level playing field' remains an explicit Commission objective. As a result, there is certainly a risk that the Commission's laudable goal of achieving a fully-integrated EU-wide digital marketplace will in fact provide cover for the introduction of new regulations that may make it harder for technology companies to do business in Europe, irrespective of their national origins.

Implementation of the DSM strategy remains at an early stage. As a result, concrete legislative proposals have not yet been put forward. The launch on 24 September of two new Commission consultations—on the regulatory environment for 'platforms, online intermediaries, data and cloud computing and the collaborative economy'; and 'geo-blocking', respectively—give a good indication of the areas of focus.

While the Commission has expressly identified the geo-blocking consultation as a precursor for legislative proposals, the outcome of the other consultation (referred to in this note as the 'platforms consultation', for simplicity) is less clearly defined, reflecting its wider scope. Given the importance and prevalence of platforms in the online world, and the often highly vocal criticism from some quarters in the EU of the disruptive impact of (predominantly American) platform-based providers of sharing economy services in particular, it is perhaps unsurprising that this specific aspect of the DSM strategy has attracted a high level of attention. As a result, it is particularly interesting to see the questions asked by the Commission on this topic.

Platforms consultation

The 46-page platforms consultation document actually covers four discrete topics:

  • online platforms;
  • liability of online intermediaries;
  • facilitating the free flow of data and use of cloud computing; and
  • the collaborative economy.

1. Online platforms

The first part of the consultation questionnaire is essentially an information-gathering exercise, with the Commission posing a number of general questions concerning the role of online platforms and issues faced by their providers and users. The consultation document defines an online platform for these purposes as "an undertaking operating in two (or multi) -sided markets, which uses the Internet to enable interactions between two or more distinct but interdependent groups of users so as to generate value for at least one of the groups." This very broad definition encompasses a wide range of online services, including general search engines, specialised search tools, news aggregators, online marketplaces, music and video sharing platforms, payment systems, social networks, app stores, gaming sites and sharing economy services, with internet access provision being the only activity specifically excluded from the scope of the questionnaire. Depending on how 'value' is defined, even dating sites and apps could be included. In other words, a large proportion of the online and app economy comes within the scope of this review.

The Commission's questions cover:

  • the social and economic role of platforms;
  • platform transparency, for example with respect to terms of use and methodology for presenting search results;
  • provision of information by platforms (e.g. concerning the use of data collected from users and pricing);
  • the relationship between platforms and suppliers, traders, app developers and holders of rights in digital content, including the extent to which such businesses may be dependent on platforms, issues faced by owners of digital content, constraints that may currently prevent platforms extending their activities across the EU and the potential for improving the relationship between platforms and suppliers by additional regulation;
  • constraints on the ability of consumers and traders to move between platforms; and
  • problems relating to access to data experienced by users of online platforms.

Overall, the questions are rather general in nature, with the Commission's main objective appearing to be to verify the extent to which issues that have been raised with officials (particularly by those whose commercial interests may be harmed by the expansion of platforms) arise in reality. What is less clear is the extent to which identification of any issues may justify additional regulation, especially given the fact that at least some of the practices covered in the questionnaire are already amenable to review under existing rules relating to, for example, data protection, consumer contracts or antitrust. (It is notable, for example, that there is a significant overlap between some of the issues covered, including search methodology, parity clauses and platform dependency, and live Commission antitrust investigations.)

2. Tackling illegal content online and the liability of online intermediaries

The second section of the platforms consultation is much more specific, focusing on the question whether the ability of online intermediaries that passively transmit, store or host data to limit their liability for issues related to that data, as provided by the 2000 E-Commerce Directive, should be removed or amended. In particular, the Commission appears to be looking for evidence that the limitation may be over-generous to intermediaries and hence should be revised to create a more 'level playing field' with other market participants.

3. Data and cloud in digital ecosystems

The penultimate section of the platforms consultation focuses on Commission initiatives to tackle restrictions to the free movement of non-personal data in the EU and the development of a 'European Cloud'. On the first of these topics, the Commission is looking for information on restrictions on the free movement of non-personal data within the EU and suggestions of ways in which these could be addressed. (The free movement of personal data being the subject of separate legislative action, under the new General Data Protection Regulation.) The second part of this section concentrates on the potential for encouraging the adoption of cloud computing services in the EU, including consideration of how consumer and business confidence in such services can be increased. Questions concerning the ease of switching cloud provider and providers' bargaining power create some ambiguity, however, over whether (at least for some stakeholders) the 'European Cloud' may be as much about helping European cloud providers win market share from their American competitors as facilitating greater use of cloud services by European businesses.

4. The 'collaborative economy'

The final section of the platforms consultation questionnaire considers issues raised by the 'collaborative economy' (which appears to be the preferred EU term for what is more usually referred to as the sharing economy). The consultation defines this as linking "individuals and/or legal persons through online platforms (collaborative economy platforms) allowing them to provide services and/or exchange assets, resources, time, skills or capital, sometimes for a temporary period and without transferring ownership rights." The questions are general in nature and appear to be aimed more at improving the Commission's understanding of the issues raised by sharing economy platforms; their effect on suppliers, innovation and consumer choice; and the regulatory environment in which they operate. Based on the questions asked, the Commission appears to be particularly interested in the impact of the collaborative economy on transport, tourism, accommodation, the audiovisual sector and professional services.

This focus presumably reflects the explosive growth of certain ride-sharing and accommodation sites and the attendant backlash from incumbents. Consistent with this, the Commission appears to be particularly concerned with ensuring that there is a 'level playing field' between providers in the collaborative economy and traditional providers, by exploring whether specific legislation is required (without specifying whether this would be to assist or constrain sharing economy services) or whether the focus should be the improvement and enforcement of existing rules.

Geo-blocking consultation

'Geo-blocking' (i.e. a range of practices by which businesses block access to certain websites or content on the basis of a user's location) tends to be viewed as a particularly tangible challenge to the concept of a single EU-wide market in goods or services. Commission Vice-President for the Digital Single Market Andrus Ansip has described geo-blocking as fundamentally incompatible with the concept of an internal market, whereas Digital Economy Commissioner Günther Oettinger calls it "one of the most visible manifestations of non-Europe". It is therefore unsurprising that the Commission has identified such practices as a central target of the DSM strategy. For example, geo-blocking is a focus of the Commission's e-commerce antitrust sector inquiry, which was launched back in May, as well as ongoing antitrust enforcement cases.

The geo-blocking consultation questionnaire is shorter than the platforms questionnaire and is primarily concerned with gathering information on difficulties faced by those seeking to access information, or to shop for goods and services, across borders in the EU. The questionnaire asks for examples of specific geo-blocking practices, information on the impact of such practices upon consumers and businesses, whether SMEs should be exempt from any regulatory measures limiting geo-blocking, whether implementation of any policy response would be more effective at national or EU level and which bodies should have responsibility for enforcement of any new measures.

The consultation is intended to inform possible legislative changes, including revision of the e-Commerce Directive and Article 20 of the Services Directive. The latter already prohibits discrimination in the provision of services on the basis of place of residence (albeit subject to broad exceptions). The use of geo-blocking to limit access to digital content that is protected by copyright, such as movies, music and games, is outside the scope of this consultation, since it is being addressed by separate initiatives aimed at reforming European copyright laws.

Commentary

The deadline for replies to both consultations will be 12 weeks from the release of the questionnaires in all 24 official languages of the EU. Although the clock is not yet running, since the questionnaires have not yet been translated into every single official language, the Commission has indicated that the deadline is likely to expire late in December. While responses may be submitted in any official language of the EU, the Commission has tactfully indicated that responses in English, French or German are likely to be processed more quickly.

These questionnaires are just part of a flurry of consultations recently initiated by the Commission relating to the DSM strategy. The day before these two consultations were launched, the Commission initiated a consultation on technical standards and interoperability, while the following day saw the launch of a consultation on modernising value-added tax for cross-border e-commerce. These are in addition to ongoing consultations on revising the Cable and Satellite Directive and the Audiovisual Media Services Directive and a wide-ranging review of the EU telecoms regulatory framework.

Notwithstanding this deluge of consultations, it is difficult at this stage to predict quite what the result of all this activity will be (apart from in one or two specific areas where focused reviews of existing laws have been rolled up into the DSM strategy). While it is clear that the Commission is determined to break down barriers to trade within the EU, including through passing new EU-wide legislation in at least some areas, much of the detail remains unclear.

This uncertainty is in large part due to the inherent tension between the two motivating forces behind the entire DSM strategy. While public comments by Commissioners have largely focused on the need to address consumer and business dissatisfaction with the fragmented nature of digital markets in the EU and the desire to make it easier for businesses of all sizes to use technology across the EU, aspects of the Commission's strategy indicate a more defensive motive, namely to protect incumbent European businesses from disruptive competition from new rivals (which often happen to be from the US). Hidden behind the catch-all call for a more 'level playing field', which is often heard by Commission officials in DSM-related discussions, is the fact that, in many markets, traditional business models are subject to extensive EU and national regulation that may not apply to new disruptive business models. Such regulation may specify, for example, the amount of local language content that must be shown by a broadcaster, the type of vehicle that a taxi operator must use or minimum safety standards for hotels. The question whether the best response to such disparities may be to reduce the level of existing regulation on incumbents, rather than impose additional regulations on disrupters, is in many ways a philosophical one but one that will ultimately need to be addressed by the Commission once all the consultations are complete.

[View source.]

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.

© Cooley LLP | Attorney Advertising

Written by:

Cooley LLP
Contact
more
less

Cooley 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.