California Appellate Panel Affirms Injunction Blocking Use Of Employee Non-Solicitation Provision In Dispute Between Travel Nurse Providers

Seyfarth Shaw LLP
Contact

[co-author:

On November 1, 2018, the California Court of Appeal, Fourth Appellate District affirmed a trial court’s ruling in AMN Healthcare, Inc. v. Aya Healthcare Services, Inc. et al., Case No. D071924, Cal. App (2018) which (1) invalidated the plaintiff’s non-solicitation of employees provision in its Confidentiality and Non-Disclosure Agreements (CNDAs), (2) enjoined AMN from enforcing or attempting to enforce the employee non-solicitation provision in its CNDA with any of its former employees, and (3) awarded $169,000 in reasonable attorney’s fees to defendants for plaintiff’s use of the provision. The case is a significant decision which may impact some employers’ continued use of employee non-solicitation provisions with their California employees, at least in certain industries. There is now a split in California authorities, and the issue is likely ripe for California Supreme Court guidance.

AMN and Aya are competitors in the business of staffing temporary healthcare professionals, namely providing “travel nurses” to medical care facilities across the country. When former employees, named as individual defendants in the action and who worked as travel nurse recruiters in California, left AMN for Aya, AMN brought suit against Aya and the former employees, asserting 11 causes of action, including for breach of contract and trade secret misappropriation.

The trial court granted defendants’ motion for summary judgment on all plaintiff’s claims, as well as summary judgment for defendants on their causes of action for declaratory relief and unfair competition injunction asserted in their cross-complaint. The trial court held that under California law, the non-solicitation of employee provision was an unlawful restraint on trade in violation of Business and Professions Code section 16600 because it prevented the individual defendants from engaging in their lawful trade or profession—soliciting and recruiting travel nurses on temporary assignment with AMN—for at least one year post termination. The trial court found no evidence of misappropriation of trade secrets, reasoning that the customer list of names and identities and other information at issue did not qualify as trade secrets and any  disclosure and use did not cause any harm to the plaintiff. The trial court awarded defendants their fees under Code of Civil Procedure section 1021.5 and Civil Code section 3426. AMN appealed.

AMN required the defendant former employees to sign the CNDAs as a condition of their employment with AMN. Section 3.2 of the CNDAs, the non-solicitation of employees provision, states in pertinent part:

Employee covenants and agrees that during Employee’s employment with the Company and for a period of [one year] or eighteen months after [termination], Employee shall not directly or indirectly solicit or induce, or cause others to solicit or induce, any employee of the Company . . . to leave the service of the Company . . .

Analyzing Section 3.2 of the CNDAs, the Court of Appeal independently arrived at the same conclusion of the trial court, that the employee non-solicitation provision was void as an unlawful restraint of trade in violation of Section 16600, which provides “[e]xcept as provided in this chapter, every contract by which anyone is restrained from engaging in a lawful profession, trade, or business of any kind is to that extent void.” Looking to the history of section 16600 and its broad language, as well as California case law evidencing a strong public policy in favor of employee mobility, the Court concluded that the non-solicitation provision “clearly restrained [the] individual defendants from practicing with Aya their chosen profession—recruiting travel nurses on 13-week assignments.”  Writing for the three-judge panel, Judge Benke stated that the trial court was within its discretion to invalidate the provision because “unless a contractual restraint falls into one of section 16600’s three statutory exceptions . . . it ostensibly is void.”

In reaching its conclusion, the Court cited California case law rejecting employee non-competes and “overbroad” customer non-solicitation provisions. “Indeed,” the Court observed, “the undisputed evidence in the record shows that, if a former AMN recruiter . . . was barred for at least one year from ‘soliciting or recruiting any travel nurse listed in AMN’s database,’ that would restrict the number of nurses with whom a recruiter could work . . . while employed by his or her new staffing agency” and “[n]ot being permitted to contact travel nurses who currently work for AMN could limit the amount of compensation a recruiter would receive with his or her new agency after leaving AMN.”

A crucial detail to note is the nature of the profession at issue in the case. The Court’s extensive discussion of the non-solicitation provision emphasized the fact that the job at issue is recruiting and soliciting. Defendant former employees were AMN “travel nurse recruiters” who all, for various reasons, left to join Aya as travel nurse recruiters. The ability of these particular defendants to engage in their profession, then, was directly affected by the covenant not to solicit employee traveling nurses. Based on that fact, the court rejected AMN’s attempt to analogize to Loral Corp. v. Moyes, which ultimately determined that the non-solicit of employee provision at issue was not an invalid agreement not to compete, but a non-solicitation agreement prohibiting the defendant from “raiding” the plaintiff’s employees. 174 Cal. App. 3d 268, 279 (1985). The Moyes court reasoned that the “restriction only slightly affects employees. They are not hampered from seeking employment with [the defendant’s new employer] nor from contacting [the defendant]. All they lose is the option of being contacted by him first.” The Court also distinguished AMN’s former employees from the former executive officer in Moyes, who was not similarly burdened by the restrictions set forth in the non-solicitation provision.

In its discussion of Moyes, the Court challenged the Moyes court’s “reasonableness” and slight affect approach to employee non-solicitation provisions and contrasted it with the plain language of 16600 and subsequent case law in the California Supreme Court decision in Edwards v. Arthur Anderson LLP, 44 Cal. 4th 937 (2008). The Court concluded that it “doubt[s] the continuing viability” of Moyes, and took the opportunity to further illustrate California’s uniquely strict policy against restraints of trade, even restraints subject to the “narrow-restraint exception” adopted by the Ninth Circuit in Campbell v. Trustees of Leland Stanford Jr. Univ.  817 F.2d 499 (9th Cir. 1987), which was ultimately rejected by the California Supreme Court in Edwards.  The Court reasoned that while it doubted the continuing viability of Moyes post-Edwards, “the instant case does not rest on that analysis alone.” The Court determined that even if the reasonableness standard survived Edwards, Moyes was factually distinguishable and that if the non-solicitation provision was enforced here that the individual defendants would be restrained from engaging in their chosen profession, even in a “narrow” or “limited away.”

The Court also rejected AMN’s trade secret misappropriation claim. The nature of individual defendants’ profession also played a role in the court’s conclusion that there was no evidence of trade secret misappropriation.  The Court was unpersuaded by AMN’s argument that the information at stake (the names, addresses, and identities of its “Travelers” or traveling nurses) was “secret” for purposes of AMN’s trade secret claims.  In light of the evidence, the Court explained that in the industry of temporary healthcare professional staffing, “some travel nurses work with many different healthcare recruitment firms in order to increase the likelihood that they will be placed in assignments which fit their needs.”  AMN even conceded that some of the information was accessible to Aya through independent means, for example, a social media group page for traveling nurses.

Furthermore, the Court noted that some of the traveling nurses at issue had applied for employment with Aya before they were recruited for AMN by individual defendants, or least before individual defendants joined Aya.  The Court found that a list of names and email addresses of nurses that one individual defendant took was never actually used to attempt to take AMN’s business. Thus, while it may have been “wrong” for one of the individual defendants to send some of this information to her personal email, the court found “no evidence she or Aya ever used or relied on such information to recruit, or attempt to recruit, any of the travel nurses on that [list of Travelers and their information].” The Court concluded that plaintiff was neither harmed by any such disclosure nor was such a disclosure a “substantial factor” in causing plaintiff any harm. Additionally, the Court found that plaintiff had not demonstrated the competitive information that one of the individual defendant had taken was trade secret because the information  was very general and there was no evidence that Aya obtained any economic value from the disclosure of the information.

Moreover, in rejecting plaintiff’s tort claims for breach of duty of loyalty and intentional and negligent interference with prospective economic advantage, the Court rejected the argument that the employee non-solicitation provision could be justified under a trade secret exception to section 16600.  The Court reasoned that because the allegedly confidential information was not “secret,” AMN’s agreements fell outside the common law “trade secrets exception” to section 16600.  The court also cited The Retirement Group v. Galante to reiterate that contractually preventing the misappropriation of trade secrets is not so much an “exception” to section 16600, but instead enjoining tortious conduct that is “enjoinable because it is wrongful independent of any contractual undertaking.”  176 Cal. App. 4th 1226, 1238 (2009). The Court reasoned under the Retirement Group decision that while a plaintiff may seek an injunction to prevent actual or threatened misappropriation of trade secrets, it cannot obtain an injunction to enforce a non-compete or non-solicitation provision on the grounds that the covenant is designed to protect trade secrets. The Court held that the torts claims failed because section 16600 precludes an employer from restraining an employee from engaging in his or her “profession, trade, or business,” even if such an employee uses information that is confidential but not a secret.

The Court concluded by affirming the trial court’s grant of summary judgment on defendants’ declaratory relief claim and upheld the unfair competition injunction entered against AMN. In its review of the injunction prohibiting enforcement of the non-solicitation provision against any former employees, the court examined evidence that AMN had previously brought a similar suit against an employee who left for a competitor and that AMN was continuing in its efforts to enforce section 3.2 by sending cease and desist letters to former employees upon their acceptances of employment with competitors. The Court rejected plaintiff’s contention that the injunction was overbroad or imprudently granted. With respect to the award of fees under section 1021.5 of the California Code of Civil Procedure, in upholding the award, the Court noted that this was an important issue affecting the public interest, and conferred a significant benefit on many people, i.e., all current and former AMN California employees who had signed a CNDA containing a similar non-solicitation provision. It is unclear whether the plaintiff will seek California Supreme Court review or whether employer groups will mobilize to challenge the decision through legislation or amicus briefing.

In sum, while many California courts have followed the reasoning in Loral v. Moyes over the years, there is now likely a split in authority in California concerning the continued viability of non-solicitation of employee provisions, at least in certain industries and positions, like recruiting and staffing. Going forward, plaintiffs will argue that the case is limited to its facts and the unique industry involved and point to Loral and its progeny for the continued viability of such provisions. California Supreme Court review is likely needed to resolve these important issues. Notwithstanding, this decision serves as further confirmation of California’s aggressive pro-employee mobility policy and judicial hostility towards restrictive covenants and protection of company information. Employers should conduct a careful review of their employee non-solicitation provisions with California employees to address the uncertainty created by this decision. Employers should use special care in specialized industries and positions where the non-solicitation covenant may prevent the former employee from engaging in their chosen profession.

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.

© Seyfarth Shaw LLP | Attorney Advertising

Written by:

Seyfarth Shaw LLP
Contact
more
less

Seyfarth Shaw LLP on:

Readers' Choice 2017
Reporters on Deadline

Related Case Law

"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.