California Privacy Regulations Released: Guidance and the Addition of New Requirements

Baker Donelson

Baker Donelson

On October 10, the California Attorney General issued its proposed regulations for the California Consumer Privacy Act (CCPA). The long-anticipated regulations are intended to provide guidance to businesses for how to comply with the CCPA, which has a January 1, 2020 effective date. While the proposed regulations do provide clarification to businesses for implementing consumer rights under the CCPA, the regulations also dictate new requirements not found in the CCPA. Notably, the regulations specify additional detail for what must be included in consumer notices and privacy policies, establish additional security requirements for verifying consumer requests, and require businesses to acknowledge a consumer's browser settings when receiving personal information.

The proposed regulations are open for public comment beginning December 6, 2019. The final regulations will be issued in the spring of 2020 and the Attorney General will begin enforcement on July 1, 2020. With just over two months until the CCPA goes into effect, businesses have limited time to react to the proposed regulations. Therefore, it is critical that businesses perform a comprehensive evaluation of their privacy processes, implement protocols for responding to consumer requests, and align privacy functions across multiple departments to ensure compliance with the CCPA. Organizations must understand, this is not just about writing a clear privacy notice; it is about understanding the information created, obtained, and shared as well as operationalizing certain changes to the methods currently being used. The overview below is a "high level" overview and we expect to release additional alerts over the next few weeks; however, as you will note by reviewing the information below, time is of the essence and there are a significant number of tasks businesses will need to undertake quickly. 

Notices to Consumers and Your Privacy Policy

The CCPA requires businesses to issue an initial notice outlining the categories of personal information to be collected from a consumer (Notice at Collection) and a notice of a consumer's right to opt out of the sale of personal information to third parties (Notice of Right to Opt Out of Sale). However, in addition to stating that all notices must use plain language and avoid technical jargon, the proposed regulations go beyond the initial requirements of the CCPA for what is mandated for such notices.

Notice at Collection. The Notice at Collection must be provided to the customer at or before the time of collecting any personal information. It must include: (1) a list of the categories of personal information to be collected; (2) the business or commercial purpose for which the personal information will be used; (3) the link to the "Do Not Sell My Personal Information" page; and (4) a link to the business's privacy policy. The addition of a purpose limitation requirement is akin to the European law (General Data Protection Regulation "GDPR") and means that a business may not use personal information for any purpose other than what is disclosed in the Notice at Collection.

Notice of Right to Opt Out of Sale. The proposed regulations state that the Notice of Right to Opt Out of Sale must be posted on the webpage, which you are directed to after clicking on the "Do Not Sell My Personal Information" button. The notice must include a description of the consumer's right to opt out of the sale of their personal information by the business along with a form which can be submitted online to opt out. Remember, the use of the word "sell" does not have the plain meaning it has in everyday language and organizations must make sure they have an understanding of whether their disclosures to third parties could be considered a "sale" as defined by the CCPA.

Responding to Right to Opt Out Requests. If a business receives a request to opt out from a consumer, a business is required to act on the request within 15 days from the date of receipt. A business is also required to notify all third parties with which it has sold personal information of the consumer within the previous 90 days of the request to opt out and instruct the third party not to further sell the information. A business is required to notify the consumer when this has been completed. Notably, a request to opt out is the only consumer request that does not have to be a verifiable request.

New Privacy Policy Requirements. Privacy policies are about to get a lot longer. Specifically, in identifying each category of personal information that will be collected from a consumer, a privacy policy must also identify the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third parties with whom the business shares personal information. The privacy policy must also outline the method by which a consumer may designate an authorized agent to make a request on the consumer's behalf. These new requirements will undoubtedly require businesses to review existing policies and evaluate steps for compliance.

"Do Not Sell My Personal Information" Button. Unfortunately, the proposed regulations did not provide a sample "Do Not Sell My Personal Information" button to be included on a business's website. The Attorney General noted that a sample button will be added in a modified version of the regulations after public feedback on its design.

Businesses Must Pay Attention to Browser Settings. One surprise introduced by the proposed regulations is that a consumer's browser plug-ins and privacy settings can be considered a valid communication for the consumer to exercise its right to opt out of the sale of personal information. There are many unanswered questions concerning this new requirement. Notably, whether a change in the browser settings by the consumer at a later date can serve to reverse a previous decision to opt out. Nonetheless, businesses will now need to recognize such settings form a consumer's device and work to implement methods to avoid the risk of missing a consumer's opt-out designation.

Exemptions for Businesses Who Do Not Sell. If a business does not and will not sell personal information, the proposed regulations provide that the business is not required to include a "Do Not Sell My Personal Information" button on its website and does not have to provide a Notice of Right to Opt Out to Consumers. A business claiming the exemption must also state in its privacy policy that it does not and will not sell personal information.

Opting In After Opting Out. The CCPA was silent on how a consumer could opt in to the sale of their personal information after previously opting out. The proposed regulations provide for a two-step process where a consumer must clearly submit the request to opt in and then separately confirm the choice to opt in. This is similar to the two-step process for authorizing a Request to Delete.

Online vs. Offline Distinction. Although the vast majority of information will be collected from consumers online, the proposed regulations require a business to establish procedures for notice where personal information is collected offline. So, by example, businesses must also now inform customers when obtaining phone numbers or email addresses at a point of sale in a brick and mortar store. This new requirement includes providing notices on printed forms or posting prominent signage directing consumers to a web address where such notices can be found. 

Consumer's Right to Know and Right to Delete Requests

Two of the core principles of the CCPA are a consumer's right to request that a business disclose the personal information the business has about the consumer (Request to Know) and the consumer's right to request deletion of that personal information (Request to Delete). The proposed regulations provide specific details for responding to such requests, the methods which businesses must put in place for receiving such requests, and what information can be disclosed by a business to a consumer. 

Deadlines to Acknowledge and Respond to Requests. For each Request to Know or Request to Delete received, a business must: (1) confirm receipt of the request from the consumer within ten days of receipt and (2) respond to the request within 45 days from the date the request is received. An additional 45 days to respond is available, for a total of 90 days, but a business must provide notice to the consumer with an explanation for why it will take longer to respond to the request. The tight timeframe to acknowledge these requests makes it imperative that a business develop a process well in advance to comply with this requirement. If a business denies a request, it must inform the consumer that it will not comply and describe the basis for the denial.

Methods of Submitting Requests. A business must have at least two methods in place for consumers to submit these requests, one of which must include the method in which the business primarily interacts with the consumer. In most cases, this will involve providing a link or form available through the business's website. Although recent amendments passed by the legislature have eliminated the requirement to have a toll-free telephone number as a method for submitting a request, other acceptance methods include submitting a form in person or through the mail. If a Request to Know is properly submitted and verified, the business must respond based on the personal information collected over the previous 12 months.

Two-Step Process for Requests to Delete. A two-step process is required for a Request to Delete. The consumer must submit the request and separately confirm that they want their personal information deleted. The additional step of confirmation is intended to prevent any accidental requests from proceeding with irrevocable deletion. 

Not All Information Can Be Provided. In balancing the consumer's right to know against the potential harm that could result from inappropriate disclosure, the regulations prohibit the disclosure of certain types of information. This includes a consumer's social security number, driver's license or government identification number, financial account numbers, health insurance numbers, account passwords, and/or security questions and answers. 

Verification of Consumer Requests

After much dilemma from the public regarding what would constitute a "verifiable consumer request" under the CCPA, the Attorney General's regulations set forth general verification requirements for businesses. While balancing the potential risk of harm to consumers if information fell into the wrong hands, the proposed regulations introduced new security requirements for verification. 

"Reasonable Method" Standard. The regulations require that a business shall establish a "reasonable method" for verifying the identity of a person making a Request to Know or Request to Delete. This requires the business to match the information provided by the consumer to the personal information maintained by the business or the use of a third-party identity verification service. 

Factors to Consider for Verification. In evaluating what is a "reasonable method" for verifying requests, the regulations established various factors to be considered by a business. This includes: (1) the sensitivity of the information requested; (2) the risk of harm to the consumer from unauthorized access or deletion; (3) the likelihood that malicious actors would seek the personal information; and (4) the manner in which the business generally interacts with the consumer. The regulations highlight that a business should generally avoid requesting additional personal information from the consumer in order to verify the request. 

Use of Authorized Agents. A consumer is permitted to use an "authorized agent" to submit a Request to Know or Request to Delete on the consumer's behalf. If a business receives a request from an authorized agent, the business may require that the consumer: (1) provide written permission to the authorized agent to make the request and (2) verify their own identity directly with the business. 

Password Protected / Non-Password Protected Accounts. The proposed regulations streamlined the verification process for password protected accounts stating that a business may verify a consumer's identity through existing authentication practices for the consumer's account. If the request is made from a non-password protected account, then the business is required to verify the identity of the consumer through a "reasonable degree of certainty." For a request for categories of information, this requires a business to match at least two data points provided by the consumer to two data points maintained by a business. For a request for specific pieces of personal information, a business must match three data points and receive a signed declaration that the requestor is the consumer whose personal information is the subject of the request. 

Unverified Requests to Delete Are Considered Requests to Opt Out. If a business is unable to verify the identity for a Request to Delete, the proposed regulations require that the business deny the request and treat it as a Request to Opt Out of Sale. 

Miscellaneous Provisions

Consent for Sale of Minor Information. If a business is collecting personal information from a child under the age of 13, it must receive consent from the child's parent or guardian affirmatively authorizing the sale of that personal information. The regulations set forth various methods for verifying that the person providing the consent is the child's parent or guardian including a consent form, calling a toll-free number, or checking government identification. For children over 13 years old, the business must implement a two-step process to confirm the choice to authorize the sale of personal information. Businesses will need to marry the regulations with current compliance with federal requirements. 

Businesses Must Quantify the Value of Consumer Data. A business is required to provide a notice to consumers for any financial incentive offered in exchange for the retention or sale of personal information. This is in relation to the CCPA's prohibition on discriminatory practices against a consumer for exercising any rights under the CCPA. Any such notice must include an estimate of the actual value the business places on the consumer's data and a description of the method used by the business to calculate the value of the data.

Service Provider Confusion. Contrary to the actual language of the CCPA, the proposed regulations require service providers to respond to consumer requests by providing the specific basis for denying the request. Service providers are also required to direct consumers to submit any requests directly to the business.

Record-Keeping Requirements. Businesses are required to retain records of all consumer requests, including all responses by the business to the consumer, for at least 24 months. The record-keeping requirements are more onerous for businesses which buy or sell personal information of four million or more California consumers. 


The Attorney General's regulations have provided the roadmap to businesses for how to comply with the CCPA. However, it will not be an easy road to travel. CCPA compliance continues to be a moving target and the added requirements from the regulations mean that businesses will need to go back to the drawing board to evaluate compliance mechanisms. The Attorney General has implied that, even though his office won't begin enforcement until July 1, 2020, businesses can be held accountable for noncompliance as of January 1, 2020. Therefore, all businesses which are subject to the CCPA must focus on it immediately to ensure compliance.

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.

© Baker Donelson | Attorney Advertising

Written by:

Baker Donelson

Baker Donelson 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.