Duluth, Minnesota Issues Paid Sick and Safe Leave Rules & Revises FAQs



The City of Duluth has published final rules and revised FAQs implementing its Earned Sick and Safe Time Ordinance. The Ordinance takes effect January 1, 2020 for employers with five or more employees, regardless of whether they work in Duluth.  Under the law, employees accrue, or an employer frontloads, paid sick and safe time (SST) that employees can use for themselves or to care for or assist a covered family member for the following reasons: mental or physical illness, injury, or health condition; medical diagnosis, care, or treatment of a mental or physical illness, injury, or health condition; preventive medical care; and absences connected to domestic abuse, sexual assault, or stalking. Below we discuss whether and how the rules clarify or gap-fill the ordinance's requirements.

Covered Employees

Generally: The ordinance applies to employees who perform work in Duluth for more than 50% of their working time in a 12-month period, or are based in Duluth and spend a substantial part of time working in Duluth and not more than 50% of work time in any other particular place in a 12-month period. The rules clarify that "substantial part of time" means more than 50% of working time. Additionally, the rules clarify that employees working from home, or otherwise commuting, are covered for hours worked in Duluth.

Exceptions: The ordinance does not cover independent contractors, student interns, seasonal employees, and certain railway employees. The final rules incorporate the six-factor test the city previously identified in FAQs to determine whether a worker is an employee or an independent contractor, and include a new nine-factor test specific to the construction industry. Additionally, the rules create a six-factor test to determine whether a worker is an employee or a student intern. Finally, the rules incorporate the FAQs’ definition of seasonal employee: a person employed for no more than 10 months during any consecutive 12-month period, but expected to return to work year after year. The rules say the agency will make employee status determinations on a case-by-case basis.

Using Existing Policies

Under the ordinance, employers with substantially equivalent paid leave policies that provide an amount of leave that can be used for the same purposes, and under the same conditions, as the law requires, and that comply with the law's accrual and carry-over requirements, are not required to provide additional SST. Notably, the rules clarify that collective bargaining agreements negotiated and enacted before January 1, 2020 comply with the law, but those enacted after January 1, 2020 must include a substantially equivalent paid leave policy.

Additionally, the rules address whether and how employers can comply using non-traditional paid leave policies like unlimited or untracked leave. If employers make paid leave available that employees may use for the same purposes and under the same conditions as the law requires, and may be reasonably expected to exceed the law's accrual standards, then such a policy complies.

Accrual & Carryover Requirements

Under the ordinance, covered employees must accrue one SST hour for every 50 hours worked. The rules add that hourly employees accrue SST when they work overtime hours. They also say SST does not accrue when employees use SST; this builds on an existing FAQ that says SST does not accrue when employees use vacation.

The law requires employers to allow employees to carry over up to 40 SST hours to the following year, unless they frontload 40 hours annually. Additionally, with an employee's written consent, the rules allow employers to cash out accrued but unused SST instead of carrying it over. The rules require the cash-out value to be equal to the employee's standard base pay rate.

Use of Leave

Minimum Increment of Use: Under the ordinance, employers can require employees to use a minimum amount of SST for absences if this minimum increment does not exceed four hours. The rules create an exception: if an employee's SST balance is less than the employer's minimum increment, employers cannot enforce the minimum increment and employees must be allowed to use their available SST balance.

When Employees Can Use Leave: The ordinance allows employees to use leave during a scheduled shift. A new rule stipulates employers are not required to permit SST use when an employee is suspended or otherwise on leave for disciplinary reasons. Another rule affirms employees can use SST for overtime hours they are scheduled, or have volunteered, to work.

Requesting to Use Leave: The ordinance sets a general standard for SST use requests: employers must grant leave upon an employee's request, which, if possible, must include the absence's expected duration. Moreover, the ordinance allows employers to require compliance with usual and customary notice and procedural requirement that do not interfere with the leave's purpose. The rules establish notice standards for unforeseeable absences. In these instances, employees or their spokesperson (e.g., spouse, coworker, adult family member, other responsible party) must provide notice as soon as practicable. Under the rules, employees need not explicitly reference the ordinance, but employers can ask whether the absence qualifies under the law if the inquiry does not violate the law's privacy and confidentiality provisions. The rules do not address foreseeable absences, leaving employers free to establish requirements that do not otherwise violate the law.

Documenting Leave Requests: Employers may request reasonable documentation related to SST use if the absence exceeds three consecutive days. The rules clarify the standard is consecutive days an employee is scheduled to work. They also provide examples of what constitutes "reasonable" documentation; for sick time a doctor's note, and for safe time a police report, court order, or an employee's written statement that communicates an employee or family member is experiencing domestic violence, sexual assault, or stalking and the absence was taken for a covered purpose.

Notably, the rules limit how frequently employers may request documentation under certain circumstances:  Adopting a standard only used in Saint Paul, if an employee is absent on two separate occasions, and each absence exceeds three consecutive days, employers cannot request documentation for the second absence unless more than two weeks have elapsed since the first absence. Additionally, the rules state employer requests cannot cause an “unreasonable burden or expense” for the employee. Under the rules, employees can allege the request creates an unreasonable burden or expense and provide an oral or written explanation stating they have used SST for a covered purpose. Upon receiving the explanation, an employer has 10 calendar days to identify and provide alternatives for the employee to satisfy the employer's request, which could include, for example, accepting the explanation or mitigating an employee's out-of-pocket expenses. If the parties cannot reach agreement, they can consult, or an employee can file a complaint with, the enforcement agency.

Payment When Employees Use SST

Under the ordinance, employers must pay SST at the same hourly rate the employee receives from employment. The rules establish pay rate calculations for various types of employees, in addition to standards for hourly and salaried employees the ordinance sets. For employees paid on commission and tipped employees, the hourly rate is an employee's base wage (the ordinance says they are not entitled to compensation for lost tips or commissions). For pieceworkers, employers must divide total earnings for the most recent workweek in which an employee did not use SST by the number of hours worked during that workweek. Also, the rules provide that, if an hourly employee uses SST for scheduled overtime, the hourly rate is the employee's regular, rather than overtime, rate. For indeterminate-length shifts (e.g., a shift defined by business instead of a specific number of hours), employers may determine the pay rate based on hours worked by a replacement employee working the same or a similar shift. Finally, the rules provide when employers must pay employees: the regular payday for the pay period in which an employee uses SST.

Notice / Posting Requirements

Under the ordinance, employers must provide covered employees a notice explaining their rights and protections under the law, including details about their entitlement to and amount of leave, terms of use, rules prohibiting retaliation, and that employees can file a complaint with the city. The rules expand on this notice requirement. First, they allow employers to comply by conspicuously displaying the city-created poster, which is available online. Alternatively, employers may use their own written notice, which, at a minimum, must contain the aforementioned information. Moreover, the rules define what "terms of use" means: when accrual starts; when employees may begin using SST; rate at which an employee accrues SST; maximum number of hours an employee may accrue in a year; and how SST carries over to the next year. Additionally, the rules require that, if an employer frontloads SST, its written policy must specify this to employees.

Recordkeeping Requirements

Under the Ordinance, employers must keep for three years accurate records documenting hours worked, and SST hours accrued and used. The rules clarify hours worked are those in Duluth. Although the rules allow employers to comply by using a substantially equivalent leave policy to record total hours worked instead of hours worked in Duluth, the same leniency is not extended to employers using unlimited or similar paid leave policies. With respect to hours worked, the rules provide that, for salaried employees who work in Duluth more than 50% of their yearly work time, employers may maintain records of the employee’s regular workweek hours, rather than tracking actual hours worked in Duluth, if the hours of a normal work week are used as the actual basis for the employee’s accrued and used SST.

Another recordkeeping difference the rules establish is that employers that are complying by using a substantially equivalent leave policy need not track the specific reasons employees use leave, but those using an unlimited or similar policy must. Finally, the rules explain that employers with unlimited or similar policies need not track accrual (as none occurs).

Prohibited Acts

The ordinance prohibits requiring employees to find replacement worker to cover their shifts when they use SST. The rules expand the list of prohibited conduct, including a very broad anti-retaliation prohibition. The rules say employers cannot interfere with employee rights under the ordinance. Additionally, the rules prohibit retaliating or otherwise taking adverse action against employees for exercising, or attempting to exercise, their rights, e.g., requesting or using SST, informing another person about SST or helping the individual use SST, or lodging a complaint with the city. For example, the rules prohibit counting SST an employee uses as an unexcused absence from work. They also prohibit retaliatory acts such as altering a preexisting schedule, reducing scheduled hours, delaying payment of SST, wages, or tips., However, the rules also provide examples of what does not constitute retaliation.

The rules allow employers to investigate suspected SST abuse if the investigation does not interfere with the employee’s ability to use SST. They also allow employers to take reasonable action, e.g., discipline, when an employee’s SST use is not in good faith, such as a clear instance of abuse. These rules build upon existing FAQs that provide examples of a “clear instance” of abuse: using SST on days when a request for vacation was denied; contemporaneous social media photo or post that conflicts with the stated reason for using SST; a consistent pattern of circumstantial evidence, e.g., repeatedly calling in sick on Fridays.

Penalties & Enforcement

The ordinance allows the enforcement agency to asses an administrative penalty. Revised FAQs clarify the penalty amount: $200. A penalty for more than one day of a continuing violation may be imposed if the violation causes a serious threat of harm to public health, safety, or welfare, or the violator intentionally and unreasonably refuses to comply with requirements. For repeat violations – the second or subsequent offense within one year – each penalty doubles. For example, if there were four qualifying violations, the penalty for the fourth violation is $1,600 (first: $200; second: $400; third: $800; fourth: $1,600).

The rules also allow the suspension or revocation of city-issued licenses for violations. This is in addition to remedies in the ordinance, which include reinstatement and back pay, crediting any SST accrued but not credited, payment of any accrued SST unlawfully withheld, lost wages, injunctive and other equitable relief, and reasonable attorneys' fees and costs.


The Duluth ordinance takes effect in two months, leaving employers little time to review policies, practices, and procedures to ensure they comply with the law. Employers subject to more than one paid sick and safe time law – in Minnesota or throughout the country should determine whether one overall policy is feasible or whether carve-outs – such as for Duluth’s ordinance – will be necessary.  Employers should also consider the impact the Duluth ordinance may have on other policies such as payroll, time keeping and attendance.  Finally, employers should consider consulting with experienced counsel to assist in navigating these compliance challenges. 

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.

© Littler | Attorney Advertising

Written by:


Littler 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.