Deregulation is the New Buzzword in Washington — Except in the Tech Industry

Fenwick & West LLP
Contact

Fenwick & West LLP

The past year has been a volatile one, from trade wars to the government shutdown to a stock market dive. One constant that U.S. businesses have become accustomed to, however, is deregulation across a wide variety of industries — except for technology. As innovation in that sector continues at a rapid pace, regulators will continue to address consumer protection concerns. In addition, technology companies will continue facing more aggressive enforcement as well as increasingly complex regulation at both the federal and state levels.

In this article, we look at digital advertising disclosures, data privacy and internet-driven products — three areas in which regulatory oversight of tech companies has dramatically increased — and discuss what the industry is likely to face in the coming year.

The Influencer Economy

One area in which regulators and enforcement agencies have targeted the entire digital advertising ecosystem — including advertising agencies, publishers, game companies, technology networks, traditional brands and even individual talent — is influencer advertising disclosures.

Advertisers have expanded their partnerships with influencers in recent years, and analysts estimate that spending on influencer marketing could reach $10 billion by 2022. Social media and content platforms have also invested heavily in this sector. (Facebook, for example, launched a search engine in June 2018 called Brand Collabs Manager to enable brands and content creators to search for partners with similar audiences.)

The Federal Trade Commission is the primary federal agency that regulates endorsements and testimonials. The FTC has authority under Section 5 of the Federal Trade Commission Act to prevent “unfair” or “deceptive” business practices, which includes online advertising and sponsorships. As early as 2009, the FTC issued updated guidelines for endorsements and testimonials specifically to ensure that disclosures are properly made in social and digital channels. The FTC stressed the importance of ensuring that consumers understand they are being advertised to in new online channels, as opposed to watching a celebrity on television, where a consumer readily understands they are being pitched a product.

In 2015, the FTC weighed in further on native advertising disclosures to push for disclosures that would delineate the blurred lines between editorial and advertising in digital and social channels. In the Native Advertising Guidelines, it distinguished between traditional product integration you may see in games or television and similar placements online, stressing that “deceptive door openers” such as headlines and content that appear editorial in nature are inherently deceptive and lead to consumers interacting with advertising that they otherwise may not have chosen to consume. During the same period, the FTC has also brought numerous enforcement cases against agencies such as Deutsch LA and major advertisers such as Lord & Taylor, as well as influencer networks and content and game studios, for failing to ensure sponsored posts on social media and in editorial were adequately disclosed.

In the past two years, the FTC has significantly expanded its enforcement efforts. It has continued to pursue cases against advertisers and brands, and issued further concrete guidance in its Endorsement Guides as well. For example, it reached a settlement agreement with Creaxion in fall 2018 for paying athletes to promote a client’s mosquito repellent. Creaxion reviewed and monitored promotional posts in advance, but did not require that the athletes disclose they were paid for their endorsements.

Since 2017, the FTC has also been enforcing sponsorship guidelines directly against influencers and content creators. In April 2017, the FTC sent over 90 warning letters to influencers and marketers related to disclosures of sponsored content or promotions on social media. That September, the FTC brought its first complaint directly against two influencers for falsely claiming that their reviews on social media were independent, and for failing to disclose their positions as owners and officers of the company they promoted, CSGO Lotto. The FTC has made it clear that all participants in the digital ecosystem are responsible for ensuring that advertising is clearly and conspicuously labeled.

We now see other agencies weighing in as well, most notably the U.S. Securities and Exchange Commission. In 2018, the SEC reached a settlement with professional boxer Floyd Mayweather Jr. and music producer Khaled Khaled (known as DJ Khaled). The SEC alleged that each individual promoted initial coin offerings on social media without disclosing that they received payments for their endorsements. Mayweather and Khaled paid over $300,000 and $100,000 respectively in connection with the settlement agreement.

Beyond expanded enforcement efforts by the FTC and SEC, influencers, media companies and brands also face — and will continue to face — increased pressure for self-regulation as well as scrutiny from the National Advertising Division, a division of the Better Business Bureau, on what constitutes sponsored content that requires disclosure. In one 2016 example, NAD investigated a partnership between People Magazine and the online shopping platform Joyus, and found that listing sponsored products and linking to sponsored content in People’s “Stuff We Love” section was advertising rather than editorial content. NAD recommended that the magazine implement changes to include adequate disclosures on this sponsored content. In another example, NAD recently investigated a shopping guide on skincare products that included monetized affiliate links. NAD ultimately found that the shopping guide was not advertising and was therefore outside its jurisdiction, because the editors created content independently without any input from their marketing team or the listed retailers and brands. However, NAD left open the possibility that editorial content with affiliate links could be considered advertising under other circumstances.

Overall, as the influencer economy continues to evolve, regulators will have to grapple with new issues to ensure consumers are protected adequately in the online marketplace. One such example is how regulators will treat CGI influencers such as Shudu Gram and Miquela Sousa . Also, whether such influencer marketing is deceptive on its face or whether the reasonable consumer now simply expects to be advertised to in this manner, similar to a television commercial.

Data Privacy

The next area in which technology companies have experienced greater regulation at both the federal and state levels since 2016 — and will continue to need to make a top priority — is data privacy. Monetization and leverage of large consumer data repositories has become integral to corporate growth strategies across technology and other industries. Some analysts have called big data the “new oil.”

Historically, the United States has regulated privacy by sector, with unique frameworks for different categories of sensitive data, such as health or financial information. Various state and federal agencies also have authority to pursue actions based on unfair or deceptive practices, like failing to disclose how a user’s data is shared with third parties or sharing data in violation of a stated privacy policy. In the past two years, enforcement actions under existing laws have resulted in record-breaking penalties. This is the case not only in the United States but elsewhere as well, as enforcement of the EU’s new regulations under the General Data Protection Regulation come into effect. Any company that collects or uses data from EU residents is subject to the GDPR, and U.S. companies with an EU presence now have additional risk exposure. This can even affect deals between U.S.-based companies, for example, as part of due diligence for potential acquisitions. In addition, large technology companies have come under heightened scrutiny by legislators, particularly in light of major security breaches and potential misuse of data.

Last fall, enforcement agencies reached record-breaking settlements related to data breaches. For example, Anthem agreed to pay $16 million for claims under the Health Insurance Portability and Accountability Act. The data breach underlying those claims resulted in over 78 million records compromised. In addition, a multi-state settlement agreement related to a failure to disclose a data breach required a $148 million payment. And the New York attorney general reached a $5 million settlement agreement for claims under the Children’s Online Privacy Protection Act, the largest fine to date under that statute.

Technology companies also faced several highly publicized investigations into their data privacy practices by Congress and enforcement agencies in the past year. These actions have even taken place at the municipal level. The city attorney of Los Angeles, for instance, recently sued the Weather Channel for failing to disclose that location data collected through the company’s mobile app may be used for commercial purposes like targeted marketing.

This past year, California passed a sweeping privacy law that adds significant disclosure and other compliance obligations for any company that collects consumer data. This law will come into effect in 2020 and will further increase regulatory exposure. Similar to the GDPR in Europe, California’s new law broadly defines personal data to cover almost any information related to an identifiable individual, expands notice obligations for companies that collect user data and creates new rights for users to request access or deletion of their data. In addition, companies may face greater liability in private suits based on statutory damages under the new law.

In response to the increasing complexity of the regulatory landscape, major technology companies have begun to lobby for a federal privacy law. 2019 and 2020 will be key years for the development of further U.S. privacy regulations, and in determining how much control consumers will have over the ownership and right to manage their own personal data.

To handle both consumer expectations over the management of their data and increased regulatory scrutiny, technology companies will need to continue to adapt to this new environment. In addition, ‘privacy by design’ may become less of a catch phrase and more of a term requiring deeper integration by U.S. tech-enabled businesses. And with the rise of smart cities, states and cities themselves will have to understand how they are collecting or enabling the collection of data on their residents.

Connected Devices

As data privacy issues have drawn greater attention, regulators have increased scrutiny of connected devices. The market for internet of things devices has grown rapidly in the past two years, and analysts predict that it could grow to $520 billion by 2021. IoT devices pose unique security risks. They can collect sensitive data (e.g., security cameras) or be used for purposes that could pose a safety risk in the event of a breach (e.g., an automated vehicle or a traffic light). The FTC has pursued actions against device markers as early as its 2013 settlement agreement with TRENDnet, and published guidance on best practices for IoT device makers in a 2015 report, including security-by-design and transparency about data collected.

Until recently, the FTC advocated a “wait and see” approach to the IoT ecosystem. That said, since 2017, it has reached significant settlement agreements with IoT device makers, and new legislation at the state and federal level is targeting IoT devices. Furthermore, IoT device makers have faced enforcement actions related to data collection practices, and additional inquiries from lawmakers. A major TV manufacturer paid $2.2 million as part of settlement with the FTC and the State of New Jersey in 2017 based on claims that software pre-installed on “smart” televisions collected viewing data about 11 million users without their knowledge. In 2018, electronic toymaker VTech settled FTC claims under COPPA that a mobile app connected to its toys collected personal information from children without their parents’ consent. And this past summer, several U.S. senators sent letters to device manufacturers and the FTC requesting that regulators investigate the business practices of makers of IoT devices with passive listening features.

IoT device makers must also comply with new guidance and legislation governing connected devices. For example, in September 2018, California passed the first law governing IoT devices. It requires that IoT device makers implement “reasonable security features” that are appropriate to the type of device and the nature of the data it processes. There are also sector-specific regulations and laws on the horizon for IoT device makers. For example, the Senate is considering a bill governing autonomous vehicles, the AV START Act, which will increase federal oversight of the testing and deployment of autonomous vehicles.

What to Expect this Year

U.S. businesses will continue to use data and technology as a means of creating efficiency and innovation in the marketplace. In fact, many of the largest technology companies are accelerating this process, expanding into new cities and hiring at a rapid pace. In certain areas of the tech sector — including digital advertising, connected devices and digital health — innovation is still in its early stages, but we will continue to see growing adoption of their products and services by both companies and consumers.

Although regulators are in catch-up mode, they are looking with an eye to the future, for example, by considering the imposition of trade restrictions on certain technologies, including artificial intelligence. The federal government will certainly continue to focus on the tech industry — both from a consumer protection perspective as well a fair trade perspective in regard to competition from China and others — but tech companies should also expect much more by way of state and local regulations in 2019, with California at the forefront.

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.

© Fenwick & West LLP | Attorney Advertising

Written by:

Fenwick & West LLP
Contact
more
less

Fenwick & West 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.