Ballard Spahr Interviews Two Leaders of the Colorado Information Security Community

by Ballard Spahr LLP

As part of the Rocky Mountain Information Security Conference hosted in Denver from May 8 to 10, 2018, Ballard Spahr Privacy and Data Security attorney David Stauss sat down with Robb Reck, Chief Information Security Officer for Ping Identity and Alex Wood, Chief Information Security Officer for Pulte Financial Services. The group discussed a wide-range on cybersecurity issues as well as Robb and Alex’s involvement with the RMISC and their weekly podcast Colorado = Security.

David Stauss (DS):     Thank you both for joining us today.  I would love to start by having you talk a little bit about your background.  Robb, maybe we can start with you. You are the Chief Information Security Officer for Ping Identity?

Robb Reck (RR):        Yes.  We are a software company here in Denver, about 630 employees around the world, about half of those in Denver at the headquarters.  Previous to Ping I worked in financial services in a few different companies doing online banking, doing mortgage work, doing actual – a bank itself so I’ve had a good run of regulatory requirements and then, of course, GDPR, that’s a real top of mind for us at the company – a significant amount of work going on in Europe in addition to doing that as my fulltime gig I’ve also been really involved with ISSA here in Denver, which is the Information Systems Securities Association.  Denver has the biggest chapter in the world.  We’ve had good growth there.

DS:        Alex, why don’t you tell us a little bit about yourself.

Alex Wood (AW):      I’m the Chief Information Security Officer for Pulte Financial Services.  So that is made up of Pulte Mortgage, PGP Title and The Pulte Insurance Agency. We are the wholly owned subsidiary of PulteGroup, one of the nation’s largest homebuilders. Pulte Financial Services provides those financial services for folks that are buying Pulte homes.  I’ve been doing information security for almost 20 years now. I started my career at IBM.  I did a lot of managed security services work there. We had a security operations center that I helped stand up, helped develop some of the services that they had there, spent some time after that at AT&T working in their cloud services group, among other things.  I then left there to go from a several hundred thousand person company to an oil and gas company here – QED Resources, which is just up the street from where we are right now to start their information security program, a company of 600.  So, it was a little bit of a change there.  I left there and spent some time at Kaiser Permanente doing technology risk management for them.  Then, a few years back, I moved over to Pulte to run their information security program.

DS:        One thing I want to talk about is the reason why it makes sense to have both of you in the room with me at one time and that’s what you are doing with Colorado = Security.  I’m not sure who would want to take the lead but I think it’s great what you’re doing and I think our readers would be interested in it.

AW:         For sure.  Along with Robb, I’ve spent a lot of time with ISSA.  Robb and I were on the board of the Denver chapter together for several years and formulated the idea that Colorado is this amazing ecosystem for information security.  We were involved with ISSA but there’s also a bunch of other organizations that are doing information security – ISSA, ISACA, Cloud Security Alliance, OWASP. There’s also a bunch of startup companies in the area. Ping being one of those. LogRhythm.

So we thought there are all these great things going on, but we really need to promote all of that stuff. So we want to, instead of creating one more event or one more thing that’s going on, we want to be sort of be an umbrella.  Colorado = Security was born to try and aggregate and promote all that stuff around information security that’s going on in Colorado.  Part of that is a podcast and we are recording this right now and we’re going to simulcast this with your blog.  We also have a website at where we have an event calendar.  We have a listing of companies.  We have security organization listings.  All this kind of stuff.

RR:        Good stuff we do there.  I’m going to try and stump you, David.  How many security professionals would you guess that there are here in Colorado?

DS:       I don’t know.  2,000?

RR:        According to the Colorado Technology Association, there are about 18,000 security professionals here in Colorado.  That’s a massive number, right? When I first got involved I didn’t even know where to start, right?  What do you Google to go find other professionals doing security?  So, I happened to come across ISACA and ISSA which are probably, definitely the two biggest and I got involved with them.  But then as we were doing it, we were finding all these other groups. There is this one over here and this one over here and we realized there’s just no place where you can go see what are all the options. So, that’s Alex’s point – that we became the place where you can find out what are all the options.

DS:       How long have you been running Colorado = Security?

AW:        A little bit over a year.  Our first podcast, which I think you can call our launching, was February 2017.

DS:        And you’re doing weekly podcasts?

AW:        We haven’t missed a week yet.

DS:        And every week you do an interview of someone within the marketplace.  Is that right?

AW:        Yes, so the podcast format is the first 15 or 20 minutes is local news.  We’ll go through what was the big news in the Colorado tech scene over the last week. We’ll go through blog posts and press releases from the local companies.  We’ll talk about job openings that look interesting to us, and we’ll talk about the security events that are happening over the next two weeks. That’s the first 15-20 minutes.  We then have the feature interview and that’s usually either sitting down with a founder of one of these local tech companies, a CISO from one of the local companies here in town, or just somebody else interesting in the community.  We’ve talked with heads of the different non-profits in the area.  We try and find folks who we think you would be interested in getting to know.

DS:        How has the podcast been received so far?

AW:        Terribly. Everyone hates it. Am I right?

RR:        Yeah, pretty much.

AW:        I think things have been going really well. We have gotten great feedback from people. The listenership has continued to slowly grow. We actually have one piece of feedback from a listener that made me feel really good.  He is up in Fort Collins.  He is not even in security. Just in general IT work and started listening to the podcast on his drive from Fort Collins down to Denver for his job. And, it really sort of inspired him and he refocused what his efforts were at work and was doing more on security and really invigorated him because he was sort of run down and not inspired in his job. It is good feedback like that helps me to keep doing this stuff.

DS:        How can people sign up for your podcast?

AW:        You can go to and find links there.  Or if you search for Colorado = Security on ITunes or Google Play you will definitely find it there as well.

DS:        Let’s change topics.  I want to ask about your roles and, as you know the readership on Ballard’s blog is legal based, so I want to get your thoughts right now on the relevant legal topics.  Robb, you mentioned GDPR?  How much of your time right now is spent thinking about GDPR?

RR:        Well right now it is not too bad but for the last year and a half it has been one of the overarching projects for us to get in front of. As a provider of SaaS services we had three different ways we had to think about GDPR.  We had to think of it from the prospective of our SaaS product so any data that we have in the cloud for our customers’ consumers, so we are B to B we only sell to businesses.  But they have lots of consumers who might be there and we need to help our customers comply with GDPR because no one is going to buy a solution that puts them immediately out of compliance with the biggest privacy regulation ever.  Right?  So we have to make sure our SaaS products were compliant.

Second aspect, is that we had to look at our marketing practices. For most companies, marketing is not a core IT competency where you’re especially good at all this stuff. It really causes you to mature, make sure we had data flows in place for every place where you ingest data. Where is the data being stored?  What’s the process for doing opt in/opt out? Really getting good at understanding the privacy and consent aspects for our marketing practices.

The third aspect, which is honestly the easiest one, is getting arms around privacy from an employee perspective. As a 600-something person company we have, call it seventy employees who are EU citizens. We have to treat their data in the way that is compliant with GDPR as well. So, HR systems, all those things have to be compliant.  And I kind of walked through them in the priority order that we looked at them and where we were spending our time as well.

DS:        How much time you had to devote to getting GDPR compliant over the last year or so?

RR:        It went in waves.  I’d say a year-and-a-half ago is when we created – and let’s call it December of 2016 – is where we created a matrix of product requirements that we would have to implement in order to make our products compliant with GDPR. All of December and maybe a couple of weeks of January my GDPR team was focused on creating that matrix of requirements. We delivered that to our product team in January 2017 and then we were able to hand that off and really take a back seat on that. Let them work on building their requirements into the products.  Then mid-2017 is when we really ramped up the other two aspects of the project.  The marketing and the internal projects. That’s also when we went out and contracted with an external DPO – Data Protection Officer, which is a requirement of GDPR. We did not want to have an internal person for a variety of reasons, but we chose not to have an internal person be a DPO. We engaged with an external DPO, who will give us some help with some templates and really give a little bit of guidance.

DS:        Did you feel like there was enough guidance out of the Article 29 working party to direct your efforts in getting compliant?

RR:        No.  It’s really difficult to just use their working papers, especially because different countries have different interpretations.  The regulation itself is just not nearly detailed enough.  It’s principle-based. And some of the principles sound really simple: Privacy by Design, the right to be forgotten, the right to erasure. These things sound simple, but when you start getting into the nitty-gritty of them, when you start actually trying to implement them is where you realize that it’s just not clear enough to make it easy.

DS:        Do you think this will be sort of a rolling compliance issue for you.  The May compliance deadline will happen and you’ll adjust as time goes on?

RR:        We believe that we have implemented controls that meet all the requirements. However, as we start to see case law, and I looked around this, I suspect our interpretation, everyone’s interpretation of these things is going to change.

DS:        Have you sought any certifications, like ISO 27001, to drive compliance?

RR:        We are ISO 27001 certified as of March 30 this year.  That was also a big priority for us over the last year or two.

DS:        Did you do that as part of the GDPR or did you do that separately?

RR:        It’s unrelated to GDPR.  It is really just to be able to provide assurance to our customers that we’re operating in an environment that they would be comfortable with. GDPR drives this in a different direction, which is really more about the consent and privacy and data handling versus internal security practices.

DS:        One thing that we have heard from our clients is about the seventy-two hours that you are given to provide notification of breach. How does Ping approach that?

RR:        That’s dependent on whether you are the controller or the processor.  The controller being the person who is ultimately responsible for that seventy-two hour, that timeframe, to process. The processor is the one who is kind of a supplier to the controller.  We are both. In the event of one of our employees or the marketing data, we are the controller.  In the event of our SaaS product we are the processor. So for a processor you have to let your customer know immediately. What does immediately mean?  That’s not defined.  But that seventy-two hours is applied directly to our customers from the time that we let them know until when they have to disclose.

DS:        Alex, has GDPR been at all relevant to your business?

AW:        Our mortgage and title operations only lend and insure homes in the United States. So, it has been a much smaller burden for me than it has been for someone like Robb who not only markets to folks in EU but has EU employees.

DS:        What are legal issues that are on your table right now?

AW:        We have a whole lot of consumer data that we work to keep safe every day. So, there are all the different U.S. state and federal privacy laws that we have to deal with, and that’s always a big deal for us.

DS:        Post-Equifax, the amount of state and even a little bit of federal action on privacy issues, breach response issues, the SEC cybersecurity disclosures and all these little bits and pieces that have come out, how much does that impact your lives in your positions as CISOs?

AW:        I’m pretty lucky in that we, the mortgage industry, there’s lots of regulation, so we work in tandem with our legal and compliance teams, who are pretty good in keeping up with that stuff. That doesn’t directly affect information security. But, because of that they have staff that is dedicated to following those compliance issues as new laws come out.  So, it’s like I have a little bit of extra staff to help me do that stuff. That partnership is best practice in the industry. It’s been really beneficial to have those folks help and let me know when something new is coming out.

DS:        Robb, is U.S. law a hot ticket item right now for Ping?

RR:        I don’t think so. We are really not regulated by much of what you just said. We are not a public company so the SEC is not a factor.  Certainly we are well aware of breach requirements and we have outside counsel and internal counsel that help us with that if we ever need it. We’re driven much more by what our customer’s requirements are. So, by trickle down economics we get the same requirements that are imposed upon our customers.  We do sell to large enterprises so, GLBA, HIPAA, Sarbanes-Oxley. Anything that our customers are required to do, we start to see and as a result we built a program that can map across all those different requirement sets. So, we are able to talk to them, although we are not directly regulated under any of those.

DS:        Colorado obviously is a big focus for you two. The Colorado legislature has legislation now that it is considering that would change the breach notification law and also enact some requirements on implementing and maintaining reasonable security measures. Has that been relevant at all to your businesses?  Is that something you are tracking?

AW:        It’s been on my radar, being a financial services company. We are making sure that there is not anything new that’s going to take us by surprise.

DS:        Let me ask you about the New York Division of Financial Services, cybersecurity rules. Was that something that you had to go through the compliance period last year?

AW:        The recent New York rule impacts financial and insurance companies. We lend in the state of New York.  So yes, that was something that we had to address.

DS:        How much of a lift was that for you?

AW:        New York is one of several states that have enacted or are considering enacting new cyber security laws. A company needs to be tracking these new and proposed laws and then integrating their requirements into its security compliance program. Each time one of these laws are passed, a company needs to evaluate what the new rule requires and then determine if it meets the requirements. New York is one of the more stringent laws, so I think that a lot of financial institutions that do business in the state went through an assessment of its requirements against their own practices.

DS:        Let me ask you about something else that you are involved in, which is the Rocky Mountain Information Security Conference.  Why don’t you tell me a little bit about it, Alex.

AW:        The Rocky Mountain Information Security Conference is the largest information security conference in the region.  It has been put on for over 13 years jointly by the Denver ISSA and ISACA chapters.  They get together every year and figure out what they want the conference to look like.  We have it here in May.  It is three days this year.  We’ve got one day of pre-conference full or half day trainings and then two days of sort of a more traditional conference format.  We’ve got a keynote in the morning, blocks of hour long speakers during the day, and then a keynote in the evening. I have been involved in the Rocky Mountain Information Security Conference since 2010 and I think it has been awesome. It has been growing every year.  We are going to be well over 1,000 attendees this year. I think it is really a great experience. The place to be if you are a security person in Colorado.

RR:        Alex is the co-chair of the conference. ISSA and ISACA both name a chair. He is the ISSA chair for the conference.  I am the head of programs for it.  As Alex points out it’s just a phenomenal group over the years.  It’s a lot of fun.

DS:        You both will be hosting a panel on CISO leadership.  Can you tell me a little bit about that.

AW:       One of the sessions that we are having CISO panel. I am going to moderating. Robb is one of our panelists. We also have Sam Masiello from Gates Corporation, Gail Curry from Oracle, Rich Light from the Secretary of State, and Joe Macomb from Janus Henderson.

RR:        And we are recording before the panel but I can guarantee you that I am going to get into a fight with Joe Macomb during the panel.  You guys can go look and see how it went.

AW:        I am sure it will be a friendly fight, no fisticuffs.

DS:        From my perspective, legal based readers, what is your sweet spot for the types of people who should be looking to attend this event?

RR:        There are all kinds of different tracks.  Probably the track that would be most relevant to the followers of your blog is our government risks and compliance or the audit and compliance track. We really get into a series of stuff that isn’t as technical in nature. I know that the technical stuff can be a little bit intimidating. But, we have stuff talking about GDPR separating from fiction.  A couple of different GDPR tracts. We have one talking about auditing as people move to the cloud. We talk maturing third party risk management. Really I could keep going but there are a lot of different tracts that are not as technical in nature that would probably be really relevant to these folks including some lessons learned from incidents. If you want to talk about what did somebody else go through when they had a security incident. That would be a good place to learn there.

AW:        Also the elephant in the room in David is that you are speaking at Rocky Mountain Information Security Conference. I don’t know if you want to talk about what it is that you are going to be talking about?

DS:        Sure.  The basic theory of the panel is that so much time and effort has been devoted over the last or so to GDPR compliance, but that in the wake of Equifax, US law has changed substantially and is consistently changing and it is actually a far more difficult compliance or regulatory structure than GDPR because rather than having one regulation that governs what you need to do you have 50 different state laws and federal requirements as well. So we are going to talk about how all these laws are evolving and the trends that we see in the last couple of years.

AW:        One other thing I wanted to talk about with regard to the conference this year is that the first night of the conference we are doing something different than we have in the past. In the past, we brought in a big name speaker, somebody like a Kevin Mitnick or John McAfee.  This year, we are doing it a little bit different. We are trying to organically get people down there for opening night and are doing two things.  One is we are doing a job fair.  Hiring people in the information security industry is very hard right now.  There are lots of companies looking for people. There are lots of people coming into the security industry who are looking for jobs.  The second piece is that we are doing a community night with organizations. Some of those organizations that we talked about earlier:  ISSA, ISACA, OWASP, Cloud Security Alliance. They are going to have representation there.  Everybody is going to have some space where they can do presentations, talk about their organizations, give some content so if people are already members of those organizations, they are welcome to come. If they want to learn about those organizations, they are welcome to come down to the convention center and hear more about that. We are trying to make it more community based, more organic to try and get people down there for that opening night of the conference.

DS:        Where should people go for more information?

AW:        The conference website is  It is going to be held May 8 through 10th at the Colorado Convention Center.  That opening night, it is open so you don’t have to be registered for the conference to come to the job fair or the community night.  Even if you are not planning to attend the full conference, you are welcome to come down and hang out during that time.

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.

© Ballard Spahr LLP | Attorney Advertising

Written by:

Ballard Spahr LLP

Ballard Spahr 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 (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

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 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 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 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

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:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (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
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit 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 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:

- 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.