Cybersecurity Update: 2018 — A Year in Review

by Kramer Levin Naftalis & Frankel LLP

Kramer Levin Naftalis & Frankel LLP

This Update highlights key legal and policy developments in cybersecurity and privacy law that may impact important trends for 2019 and beyond. A central takeaway from 2018 is that regulators in the U.S. and abroad are increasing their scrutiny of companies’ data privacy practices and cybersecurity controls and procedures. This enhanced regulatory focus emerged in a year marked by high-profile data breaches and revealing disclosures about how large tech companies acquire, share and sell user data.

New Data Privacy and Cybersecurity Regulations

On May 25, 2018, the EU’s General Data Protection Regulation (GDPR) came into effect, ushering in a host of new requirements for many entities that process the personal data of EU residents. The GDPR expands the power of EU member states’ data protection authorities, allowing them to hand out potentially severe penalties for violations, including up to 4 percent of annual global revenue. Entities subject to the GDPR must ensure that they understand and document exactly what personal data they hold, as well as what data they process and transfer. These organizations will also have to tighten security, improve access control and tracking, and review confidentiality strategy. In addition, organizations must be prepared to respond to inquiries from EU residents ― who now have various new privacy rights under the GDPR ― including requests to provide access to and delete personal data. GDPR enforcement has already begun, as authorities in several member states have levied fines and issued warnings to organizations for alleged GDPR violations. Notably, France’s data protection regulator, CNIL, this month fined Google €50 million under the GDPR for allegedly failing to provide users with transparent information about the company’s data use policies.

Next year, a GDPR-like privacy law will go into effect in California. In June, the state passed into law the California Consumer Privacy Act of 2018 (CCPA). The legislation is designed to protect consumers by giving them new rights over personal information collected by businesses. The rights also create new responsibilities for businesses covered by the CCPA, including the right for consumers to learn what information is being collected about them. Consumers will also have the right to request that a business delete any personal information it may have collected from them and to disclose what personal information it is selling. The CCPA will come into force on Jan. 1, 2020, but businesses are encouraged to begin preparing now.

For more information about the GDPR and the CCPA, including a comparison of the two, please see two of our previous Alerts.[1]

On the cybersecurity front, the New York Department of Financial Services (NYDFS) continued to roll out regulations imposing significant requirements on covered entities, which include financial services companies and insurers doing business in New York. Beginning in August 2017, covered entities (with some exemptions for smaller companies) were obliged to meet the first wave of requirements, including implementing a cybersecurity program to protect information systems, adopting a written cybersecurity policy, designating a chief information security officer (CISO), and drafting an incident response plan. In February 2018, covered entities were required to submit their first compliance certification, and, by March, implement risk assessments and other cybersecurity program testing or monitoring, annual CISO reporting, multifactor authentication for external access to internal networks, and cybersecurity awareness training. By September, covered entities should have drafted written procedures for securing software development practices and policies to prevent users from tampering with nonpublic information. The entities also had to meet requirements for maintaining audit trails as well as encrypting and securely disposing of nonpublic information. By March 1, 2019, covered entities must develop cybersecurity policies concerning data held by third-party service providers. Going forward, covered entities will need to annually certify their compliance with the NYDFS regulation.

SEC Guidance, Enforcement Actions and Warnings

In February, the SEC released interpretive guidance regarding public companies’ disclosure of cybersecurity breaches. The guidance — which expanded upon the SEC’s prior guidance from October 2011 — stated that due to the “frequency, magnitude and cost of cybersecurity incidents,” companies should inform investors about cybersecurity risks even prior to experiencing a cyberattack. The guidance also stated that firms should implement policies and procedures for publicly disclosing breaches in a timely manner and for reporting cybersecurity information to senior management. Companies are encouraged to review their codes of ethics and insider trading policies to protect against corporate insiders profiting off of cybersecurity information. In particular, the SEC emphasized that companies facing cybersecurity incidents should be mindful of their Regulation Fair Disclosure obligations prohibiting selective disclosure.

The SEC’s interpretive guidance signaled several significant enforcement actions relating to data breaches. In 2018, the SEC charged two now-former employees of Equifax with trading on material nonpublic information relating to a 2017 data breach that exposed the personal information of 143 million Americans. In April, the SEC brought its first cyber-disclosure enforcement action against a public company when it imposed a $35 million penalty against Altaba, the successor to Yahoo. In September, Voya Financial Advisors, which suffered a breach in 2016, entered into an agreement with the SEC to pay a $1 million penalty and to re-evaluate its policies and procedures. The SEC had charged Voya with violating rules requiring investment firms to maintain a policy to safeguard confidential customer information from identify theft and to heed “red flag” warning signs of identity theft. This marked the first time that the SEC had charged a company with violating the so-called Identity Theft Red Flags Rule. Just this month, the SEC and the DOJ brought charges against Ukrainian hackers who allegedly breached the SEC’s EDGAR system in 2016, as well as several traders in California, Ukraine and Russia who allegedly profited from trading on nonpublic earnings results extracted in the hack.

In October, the SEC published a rare 21(a) report, pursuant to the Securities Exchange Act of 1934 (Exchange Act), warning that public companies victimized by cyber fraud could face enforcement action for failing to maintain sufficient internal accounting controls. The SEC cited Sections 13(b)(2)(B)(i) and (iii) of the Exchange Act that require most issuers to maintain internal accounting controls sufficient to provide reasonable assurances that transactions are executed with, and that access to company assets is permitted only with, “management’s general and specific authorization.” The 21(a) report cited FBI data estimating that relatively simple scams known as business email compromises caused more than $5 billion in losses since 2013. These scams involved criminals sending spoof emails from purported issuer executives to finance personnel, as well as criminals sending payment request emails from hacked vendor emails to issuer finance personnel. The report outlined SEC investigations of nine issuers across several business sectors that fell victim to these scams. According to the SEC, personnel at each of these issuers failed to follow internal protocols. These failures included disregarding or misinterpreting established procedures for authorizing payment requests, approving outgoing wires, and verifying vendor data changes. While the SEC opted not to pursue enforcement actions against these companies, the report served as a warning to all issuers that they should regularly reassess all aspects of their internal controls and training for preventing and addressing cyber scams.

For more information about the SEC’s guidance and 21(a) report, please see two of our previous Alerts.[2]

High-Profile Criminal Cases

The long-running dispute between Microsoft and the U.S. government over a 2014 warrant for emails stored on a foreign server came to an end in April. After hearing arguments on whether the Stored Communications Act (SCA) has extraterritorial reach, the U.S. Supreme Court dismissed the case as moot following the passage of the Clarifying Lawful Overseas Use of Data Act (CLOUD Act). A panel of the U.S. Court of Appeals for the Second Circuit had held in 2016 that the SCA lacked extraterritorial reach, thus preventing the U.S. government from seizing a Microsoft customer’s emails stored on a server in Ireland pursuant to an SCA warrant. The CLOUD Act updated U.S. data privacy and government surveillance laws to better reflect current technology and practices, specifically with respect to cloud computing. The law requires, with some exceptions, that when electronic communications and remote computing service providers operating in the U.S. are served with court orders, warrants or subpoenas under the SCA, those providers must relinquish data in their possession or control regardless of where the data is stored. The CLOUD Act also creates a framework to allow the U.S. government to enter into so-called executive agreements with other countries in order to facilitate requests for data. The law sets forth a process for service providers to challenge requests from U.S. enforcement agencies made pursuant to executive agreements. To date, no executive agreements have been reached.

For more information about the Microsoft case and the CLOUD Act, please see four of our previous Alerts.[3]

In June, the Supreme Court ruled in Carpenter v. United States that a criminal defendant’s Fourth Amendment rights were violated when the government obtained a court order requiring his wireless carriers to produce cell site location information for his mobile phone without probable cause. In his opinion, Chief Justice Roberts warned that the ruling was a narrow one that left the existing precedent undisturbed and would not require a warrant for records held by a third party in most cases. However, the decision is a departure from traditional third-party doctrine and could lead to new opportunities for criminal defendants to challenge a third party’s disclosure of sensitive information to the government.

Suspected State-Sponsored Hacking

Continuing a trend from recent years, actors suspected to be working at the behest of foreign governments allegedly carried out several major cybersecurity thefts in 2018.

In March, the U.S. government charged nine Iranian individuals with stealing a trove of intellectual property and other data from over 300 American and foreign universities, at least five U.S. federal and state agencies, as well as various private companies and nongovernmental organizations. The hackers allegedly worked for an Iranian company with ties to Iran’s Islamic Revolutionary Guard Corps and other government entities. Much of the stolen data was acquired through customized spear-phishing emails sent to over 100,000 university professors. The stolen data is valued at an estimated $3.4 billion.

Also in March, the Trump administration accused hackers believed to be linked to Russian intelligence agencies of orchestrating a series of cyberattacks targeting American and European nuclear power plants, water and electric systems, as well as aviation and critical manufacturing facilities. Since at least 2011, Russian hackers are believed to have breached numerous power, energy, oil, gas pipeline and industrial targets. By spring 2017, Russian hackers are believed to have had conducted intensive surveillance of and gained the capacity to compromise certain infrastructure facilities. Additionally, this past spring, the U.S., U.K. and Australian governments accused Russian state-sponsored hackers of targeting computer networks around the world ― including via equipment such as routers, switches and firewalls ― in an effort to conduct espionage and steal intellectual property.

In November, Marriott disclosed that the personal data of as many as 500 million guests of Starwood-branded properties had been exposed as a result of an intrusion that apparently began in 2014. The exposed data included passport and credit card numbers as well as information on where and with whom guests had traveled. The U.S. government has reportedly tied the breach to hackers working for China’s Ministry of State Security. The Chinese government is also widely believed to have orchestrated the 2014 breaches of the U.S. Office of Personnel Management and several health care institutions, including Anthem. These cyberattacks are thought to be part of the Chinese government’s ongoing efforts to assemble a massive database of Americans’ data for counterintelligence purposes.

Facebook and Google Face Scrutiny Over Data Privacy Practices

The data privacy practices of two of the world’s largest tech companies, Facebook and Google, were in the spotlight throughout 2018. Going forward, companies’ use of customer data will face continued scrutiny from U.S. and foreign regulators, particularly in light of the GDPR and the forthcoming CCPA.

Data privacy issues at Facebook drew near-constant attention in 2018. In March, The New York Times reported that the 2016 Trump presidential campaign had acquired access to data from at least 87 million Facebook users via Cambridge Analytica, a political data firm. In 2014, a psychology professor provided to Cambridge Analytica data gleaned from a personality survey and app offered to Facebook users. Cambridge Analytica used this data, which included data from friends of the survey participants who had never taken the survey, in connection with the designing of targeted advertising and other campaign activities. In December, Facebook’s data practices again came under scrutiny when a New York Times investigation reported that Facebook shared various types of data with large tech companies, including Netflix, Spotify, Amazon and Bing, without acquiring explicit user consent. According to the report, some of the companies had been permitted to access users’ private messages.

In October, Google disclosed that a security bug had exposed to outside developers the account information of roughly 500,000 users of the company’s Google+ service. In December, Google announced that a separate Google+ vulnerability impacted over 50 million users’ data. In light of these data security issues, Google announced plans to shutter the service in April 2019.


[1] The California Consumer Privacy Act of 2018: Summary and Comparison to GDPR

The Final Race to GDPR: Are You on the Right Track?

[2] SEC Report Warns of Potential Internal Controls Enforcement Actions Against Cyber Fraud Victims

SEC Report Highlights Financial Firms’ Cybersecurity Improvements and Shortcomings

[3] Supreme Court to Rule on Application of Stored Communications Act to Data Stored Overseas

Second Circuit Denies En Banc Rehearing of Stored Communications Act Decision in Microsoft Case

Second Circuit Rules That the U.S. Government Cannot Use a Search Warrant to Access Overseas Data

Privacy, Data Protection and Cybersecurity Alert: Microsoft Appeals Decision Requiring It to Provide E-mail Content Stored Overseas in Response to Search Warrant

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Kramer Levin Naftalis & Frankel LLP | Attorney Advertising

Written by:

Kramer Levin Naftalis & Frankel LLP

Kramer Levin Naftalis & Frankel LLP on:

Readers' Choice 2017
Reporters on Deadline

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

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

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

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

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

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

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

California Privacy Rights

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

You can make a request for this information by emailing us at or by writing to us at:

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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