Cybersecurity Lessons Learned From the FTC’s Enforcement History

by K&L Gates LLP
Contact

In 2014, cybersecurity and data breach incidents regularly made the headlines, with the reported breaches becoming increasingly large and complex. As in the past, these data breaches have inevitably been followed by a flurry of class actions and government investigations. But amid this flurry of activity, one federal regulator in particular, the Federal Trade Commission (the “FTC” or “Commission”), has unquestionably been the most prominent and active cybersecurity enforcer.

The FTC has more than a decade of experience in data security matters. Since 2002, the FTC has brought nearly 60 data security enforcement matters and settled more than 50 of those actions. The FTC’s data security activity has accelerated in recent years and likely will continue to do so. Jessica Rich, the current Director of the Bureau of Consumer Protection, leads the FTC’s consumer protection charge and recently stated that “data security enforcement remains a critical FTC priority.”[1] Director Rich has been involved in the FTC’s privacy and data security initiatives since the 1990s and has been praised as “a nationally recognized expert in the fields of privacy, data and identity protection, and emerging technologies.”[2] Her expertise and passion for this area, combined with what has been described as her “tenacious” drive, portends a continued focus on cybersecurity enforcement.[3] Since Director Rich’s appointment in June 2013, the FTC has brought about a dozen data security cases, comprising approximately twenty percent of all of the FTC’s data security matters since 2002.

In light of the increased scrutiny on data security and the heightened risks of attacks, it is important for companies to understand the FTC’s authority and expectations for data security practices. The FTC has stated that “[t]he touchstone of the Commission’s approach [to data security]… is reasonableness.”[4] In light of this seemingly flexible and subjective standard, how can a company know when it might be in the FTC’s crosshairs on data security? In this article, we provide an overview of the FTC’s authority and highlight some common compliance themes that emerge from the FTC’s enforcement history.

I. FTC Authority and Enforcement Activities Generally

A. Basis for the FTC’s Data Security Enforcement Authority

Although there is no comprehensive federal cybersecurity legal framework, the FTC has numerous enforcement tools. The Commission generally has enforcement or administrative authority under dozens of consumer protection laws.  In the vast majority of its data security actions, the FTC has relied on its power under Section 5 of the FTC Act to prohibit “unfair or deceptive acts or practices in or affecting commerce.”[5] The FTC has also asserted violations of numerous other laws in its data security actions, including the Gramm-Leach-Bliley Act (“GLBA”), Fair Credit Reporting Act (“FCRA”), Children’s Online Privacy Protection Act (“COPPA”), and regulations promulgated under those statutes, including GLBA’s Safeguards and Privacy Rules, FCRA’s Disposal Rule, and the COPPA Rule.

In many of the actions it has settled, the FTC has obtained injunctive relief covering a defendant’s conduct for 20 years.  The FTC has also sought or obtained civil money penalties for violations of the Disposal Rule, COPPA Rule, or past FTC consent orders. Possibly signaling a more aggressive enforcement strategy, the FTC has also requested monetary relief for impacted consumers in more recent actions.

B. Few Industries Are Beyond the FTC’s Reach, and Companies Can Be Held Liable for Actions of Their Vendors or Customers

Under the FTC Act, the FTC has broad enforcement authority over large swaths of the economy.[6] For example, the FTC has brought data security actions against retailers, financial institutions, health care-related companies, software and mobile app vendors and, notably, companies that sold products and services relating to data security.

Importantly, companies that do not directly market to consumers or have consumer-facing businesses can also be targets of the FTC. The Commission has brought numerous cases against companies that handle or deal in consumer information, such as data sellers, payment processors, debt brokers, and consumer reporting agencies.

The FTC has also alleged that companies are responsible for the data security failings caused by third parties, including vendors. In several cases, the FTC has alleged that the defendant was responsible for the security deficiencies of its third-party clients or end-users of its products or services. For example, in a number of cases, defendants that sold or resold consumer information were alleged to be responsible for failing to ensure that the downstream purchasers of information adequately protected sensitive consumer information. In cases where information is provided via a subscription service or where the purchaser obtains information through online access, the FTC has also sought to hold companies liable for failing to enforce policies and procedures to mitigate misuse of client accounts, such as identity authentication and password management.

C. Individuals May Also Be Subject to FTC Scrutiny

The FTC frequently uses its authority to bring enforcement actions against individuals who are alleged to have formulated, directed, controlled, had the authority to control, or participated in the allegedly unlawful acts or practices of corporate entities. In the data security realm, since 2002, the FTC has named individual defendants on their own or in addition to their affiliated companies in approximately ten matters. In five of those matters, the FTC has obtained or has requested monetary liability from the individual defendants.

II. Areas of Particular Emphasis at the FTC

A. Actual Breach Not Required to Trigger FTC Enforcement Activity

The FTC has stated that “the mere fact that a breach occurred does not mean that a company has violated the law.”[7] At the same time, the FTC’s enforcement powers do not require an actual breach as a prerequisite to bringing an enforcement action. In fact, in one of its earliest data security cases, the FTC rejected the notion that its enforcement authority depended upon the occurrence of an actual data breach.  Indeed, a review of the data security actions brought by the FTC since 2002 reflects that in almost one-third of those actions, the FTC’s claims were not based on an actual data breach. In such cases, the FTC instead generally alleged that the companies’ practices increased the risk of a data breach and/or misrepresented the extent of the companies’ data security measures.

B. The FTC Takes a Broad View of Consumer Information Requiring Protection

The typical categories of sensitive consumer information that the FTC seeks to protect include consumers’ financial account numbers and Social Security numbers. However, the FTC has also wielded its enforcement authority to protect less sensitive consumer information. For example, the FTC has brought enforcement actions against companies for their failures to adequately protect consumer email address, Internet surfing history, and social media activity. In consent orders settling actions, the FTC has consistently required companies to protect broad categories of information, including Social Security numbers; driver license numbers; financial account information; first and last name; home address; email addresses and other electronic identifiers, such as cookies or social media usernames; account passwords; dates of birth; telephone numbers; consumer photos and videos; and/or health-related information.

C. Collecting or Unnecessarily Retaining Consumer Information Increases Data Security Risk

Data security necessarily begins with the collection and retention of data that needs to be protected.  In numerous cases, the FTC has identified companies’ data collection and retention policies as unreasonably increasing data security risks and threats. For example, the FTC has targeted companies for collecting more information than was disclosed to consumers in privacy policies, such as consumers’ Internet surfing activity. The FTC has also criticized companies for keeping consumer information when they no longer had any business need for the information. 

III. Key Steps to Minimize Regulatory Risks in Light of the FTC’s Focus on Cybersecurity

A. Companies Should Comply With Industry Standard Data Security Measures

As previously noted, the FTC evaluates a company’s data security under a reasonableness standard.  In practice, the FTC has often looked at a company’s allegedly deficient data security practices in light of standard industry practices. Through its suite of enforcement cases, the FTC has essentially defined (and continues to define) those industry practices that it considers to be essential ingredients of a “reasonable” cybersecurity compliance program.

In numerous cases, the FTC has pointed to the failure to protect against well-known data security threats and vulnerabilities as an unreasonable data security practice. For example, the FTC has pointed to companies’ failures to implement free or low-cost defenses to well-known third-party hacking attacks, such as Structured Query Logic (“SQL”) injection attacks and cross-site scripting attacks, and for disabling critical security measures. In addition, the FTC has cited companies’ failures to use well-known data security measures, such as validating Secure Sockets Layer (“SSL”) certificates and employing firewalls to segregate and protect sensitive information.

The FTC has also brought actions against companies for failing to have adequate data security procedures in place. For example, the FTC has pointed to companies’ failures to keep software patches up to date and for using outdated software programs that were no longer supported. A frequently cited deficiency is also the failure to encrypt sensitive information, both while the information is being transmitted and while it is stored, thereby creating security vulnerabilities. The FTC has also singled out companies for failing to have adequate measures in place to detect unauthorized intrusions and to adequately respond to such intrusions once detected.

B. Companies Must Also Ensure That Employees Are Properly Trained and Managed on Issues Involving Data Security

In addition to guarding against outside threats, companies must also ensure that their own employees do not pose data security risks. Many of the FTC’s cases involve the company’s own disclosure of consumer information. For example, the FTC has brought actions where company employees downloaded peer-to-peer software programs for personal use, which then led to unauthorized disclosure of sensitive consumer data. FTC cases have also involved company employees stealing consumer information or accessing consumer information without authorization. The FTC has also brought cases where employees lost unencrypted hardware containing sensitive consumer information and where employees failed to test software programs, which resulted in the disclosure of consumer information. 

C. Don’t Overlook the Basics

When considering these challenging cybersecurity issues, it can be dangerously easy to overlook everyday considerations that affect the handling of physical information. Companies must also still ensure that they properly dispose of consumer information in all forms, including hard copies and paper records. The FTC has brought numerous cases involving the improper disposal of paper documents containing sensitive consumer information, frequently in the companies’ own dumpsters. In certain cases, the FTC can seek civil money penalties of $16,000 per violation [8].

*           *           *

The FTC’s enforcement history demonstrates that the Commission is looking at all aspects of data security, from the initial collection of data through responses to a data breach.  The FTC has stated that reasonable and adequate data security programs must be a dynamic “continuing process of assessing and addressing risks.”[9]  To meet the FTC’s expectations, companies, including those that have not experienced a data breach, should ensure that they have appropriate policies, procedures, and industry standard measures in place that evolve with changes in the cybersecurity landscape.

Notes:

[1] Jessica Rich, From Health Claims to Big Data: FTC Adverting and Privacy Priorities for Today’s Marketplace -- Brand Activation Association Keynote, Nov. 7, 2014, available at http://www.ftc.gov/public-statements/2014/11/health-claims-big-data-ftc-advertising-privacy-priorities-todays.

[2] FTC Announces Personnel Changes in Bureau of Consumer Protection, Dec. 11, 2011, available at http://www.ftc.gov/news-events/press-releases/2011/12/ftc-announces-personnel-changes-bureau-consumer-protection.

[3] Id.

[4] See Commission Statement Marking the FTC’s 50th Data Security Settlement, Jan. 31, 2014, available
at http://www.ftc.gov/system/files/documents/cases/140131gmrstatement.pdf.

[5] 15 U.S.C. § 45(a)(2).

[6] See id.

[7] Id.

[8] See 16 C.F.R. Part 682.

[9] Prepared Statement of the Federal Trade Commission on Protecting Personal Consumer Information from Cyber Attacks and Data Breaches, before the Committee on Commerce, Science and Transportation, United States Senate (Mar. 26, 2014), available at http://www.ftc.gov/public-statements/2014/03/prepared-statement-federal-trade-commission-protecting-personal-consumer.

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.

© K&L Gates LLP | Attorney Advertising

Written by:

K&L Gates LLP
Contact
more
less

K&L Gates LLP on:

Readers' Choice 2017
Reporters on Deadline

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

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

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

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

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

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

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

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

California Privacy Rights

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

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

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

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

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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