Florida’s Proposed Privacy Legislation: An In-Depth Analysis for Corporate Counsel

Shook, Hardy & Bacon L.L.P.
Contact

Shook, Hardy & Bacon L.L.P.

The Florida Senate and House of Representatives are considering two bills (SB 1670 and HB 963) that, if adopted, will amend Florida law to create the state’s first comprehensive privacy law (though they do not go nearly as far as the CCPA). The proposed amendments would: (1) prohibit the use of personal data in public records maintained by state agencies for unsolicited marketing purposes, and (2) require companies doing business online to provide notice of their personal data collection/use activities and allow consumers to opt out of the sale of that data to third parties.  This article takes a deeper look at the proposed amendments, provides some context for them, and discusses the likelihood that they will become law. (Spoiler alert: the proposed amendments are significant and well-intended, but currently contain some flaws that, if addressed, create a good chance of the amendments becoming law).

Proposed Amendment #1 – Florida’s Public Records Request Laws (the “Marketing Amendment”)

For better or worse, companies are increasingly taking advantage of public records request laws to engage in marketing activities and unsolicited sales requests.  Under Florida’s (and most states’) public records request laws, for example, a company can request public records (e.g., mailing lists) from state and local agencies to obtain telephone numbers, email addresses, and physical addresses that the company can then use for marketing purposes.  I was interviewed about this issue several months ago and the story garnered the interest of state lawmakers.  In theory, the current law can be misused by malicious actors who request this information to take advantage of Florida’s elderly population and engage in fraudulent activity.

The proposed legislation would amend current law by adding the following language to section 119.01 of the Florida Statutes:  “(4) Any public records requested from state agencies that include the personal data, including the name, address, and birthdate, or any portion thereof, of a resident of this state may not be used to market or solicit the sale of products or services to the person or to contact the person for the purpose of marketing or soliciting sales without the consent of the person. Such marketing, soliciting, and contact is prohibited unless the person has affirmatively consented by electronic or paper notification to share the data with a third party before the data is used for such purpose.”

While undoubtedly well-intended, the amendment suffers from a few flaws.  The first is a lack of clarity as to what is considered “personal data.”  The proposed amendment doesn’t define the term.  It merely provides a few examples.  This lack of guidance will make it difficult for a company that acquires data in public records to know whether it can use the data for marketing purposes or not.  Technically under the proposed definition, the personal data doesn’t even have to be identifiable (i.e., allow you to know the person to whom it relates), so a phone number or email address alone, without knowing who it belongs to, may be enough to be considered personal data governed by the law.  This ambiguity can be addressed by including a more specific definition or, at minimum, making clear that personal data means information that is identifiable to a specific individual.

A second potential problem is the timing of the consent requirement.  The proposed amendment requires consent only before marketing/soliciting begins; it doesn’t require consent before a release of the public records.  As a result, there’s no way, in the bill as written, for the state agency to act as a “check” to help enforce the goals this law seeks to create.  This may be on purpose — there are limitations on how a state agency can respond to a public records request and “what do you intend to do with this information?” isn’t a permissible response to a request.

One way to address this issue is for state agencies to condition the release of public records on the requesting parties’ agreement not to use the information for marketing purposes without first obtaining the individual’s consent to do so, such as by requiring the requester to check a box so stating.  (Florida public-records law, Fla. Stat. 119.07, allows “reasonable conditions” on the disclosure of public records – though the allowable scope of conditions is unclear).   This approach could have real teeth because if the company later violates that representation, it could give rise to a misrepresentation or breach of contract claim that a consumer might be able to bring as a third-party beneficiary of the agreement.  In other words, it could create a private right of action that the law as proposed does not currently have.

The lack of a private right of action leads to a third concern:  enforcement challenges.  Currently, the requirement would be enforced entirely by the Florida Attorney General, but it’s unclear how the Florida AG will learn that personal data obtained from public records was actually used for marketing/soliciting purposes.  It seems like a very difficult violation to uncover, short of a whistleblower bringing it to light.

Proposed Amendment #2 – Online Consumer Privacy Rights (the “Notice and Opt-Out” Amendment)

The second, more substantial, change that SB 1670 and HB 963 would make is amending section 501.062 of the Florida Statutes to provide Florida residents with more notice and control over how companies doing business online use their personal data.  In short, “operators” who collect or maintain “covered information” about Florida residents must provide notice about their data collection/use practices and give the consumers an ability to opt out of the current and future sale of that information.  Let’s unpack this proposed amendment:

Who Does The Amendment Apply To? 

The change applies to any “operator”, which is defined as a person (or entity?) that:

(1) owns or operates a website or online service for commercial purposes;

(2) collects and maintains covered information from consumers who reside in this state and use or visit the website or online service;

(3) purposefully directs activities toward this state or purposefully executes a transaction or engages in any activity with this state or a resident thereof.

A couple of problems immediately jump out.  There is no “and” or “or” between #2 and #3, so it is unclear whether an “operator” is a person/entity that meets just one of these three requirements, or if it instead has to meet all three requirements.  Let’s assume it’s the latter, because the definition doesn’t make much sense if one or two of the three elements are missing.

Additionally, the law explicitly states that it does not apply to operators located in Florida.  If the law only applies to companies having no physical presence in Florida, but who collect information from Florida residents online, it could implicate personal jurisdiction issues – particularly given Florida’s strict long-arm personal jurisdiction requirements.  Such issues are not uncommon in the privacy-law context, but they have yet to be litigated.  Again, the lack of an appropriate conjunctive or disjunctive operator makes it unclear whether all “operators” in Florida are exempted or just those that meet other criteria such as less than 20,000 unique website visitors per year (a basically meaningless threshold).

There are some exceptions to the definition of an operator.  For example, a company that operates, hosts, or manages the online service on behalf of an operator or processes information on behalf of the operator, is not governed by this law.  There are also carve-outs for HIPAA- and GLBA-governed entities, as well as for some motor-vehicle manufacturers that retrieve covered information from a technology or service related to the vehicle.

What Type of “Personal Data” Does This Change Apply To?

The proposed amendment applies to “covered information,” which is defined as a first and last name, an address that includes a street and name of city, an email address, a phone number, a social security number, an identifier that allows a consumer to be contacted either physically or online (e.g., a username or screen name), and “any other information concerning a consumer that is collected from the consumer through the website or online service of the operator and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable.”

An initial concern with this definition is potential overbreadth.  Unlike the Florida Information Protection Act (Florida’s data-breach notification law) which requires a name and another element of information, this law does not require both for the definition of covered information to be triggered.  An argument could be made, therefore, that collecting a physical or email address, a phone number, a social security number, or a username, WITHOUT the consumer’s name would still be considered covered information under this definition, which is highly unusual for a United States privacy law.

On the other hand, there are certain elements of what is traditionally covered information that might not be covered information under this definition.  For example, financial information, driver’s license numbers, passport information, or other elements of “personal data” under the Florida Information Protection Act are not considered covered information under this proposed law.  It’s possible that the last category of “covered information” (information concerning a consumer collected through the online service in combination with an identifier that makes the consumer identifiable) would cover those data elements, though those account numbers alone, without a link to a specific individual, would notbe considered covered information.

What Are An “Operator’s” Obligations?

The proposed amendment would impose opt-out and notice obligations on operators.  First, a consumer can request to opt out of the operator’s current or future sale of their covered information to a third party.  (NOTE:  unlike the overly-broad definition of a “consumer” under the CCPA that includes any resident of California, the proposed amendment applies a more conventional meaning of a consumer as an individual who seeks or acquires goods or services).

The consumer’s opt-out request must be verified, meaning that the operator can reasonably confirm the authenticity of the request, which makes sense for security purposes.  To that end, the operator has to establish a designated request address through which a consumer can submit a verified request.  The operator has to respond to the request within 60 days (with a 30-day extension available).

In addition to the right to opt out, the operator must provide notice (the method is not prescribed) that:

  • Identifies the categories of covered information the operator collects about consumers;
  • Identifies the categories of third parties with whom the operator may share such covered information;
  • Provides a description of the process for a consumer to review and request changes to his or her covered information;
  • Describes the process by which the operator notifies consumers of material changes to the notice;
  • Discloses whether a third party may collect covered information about a consumer’s online activities over time and across different websites or online services when the consumer uses the operator’s website or online service; and,
  • States the effective date of the notice.

These notice requirements are nothing new to state privacy laws, as they closely mirror those that CalOPPA imposed a number of years ago, but they’re new under Florida law.

How Will The Proposed Notice and Opt-Out Amendment Be Enforced?

The amendment states that it does not create a private right of action against an operator. Instead, it will be enforced by the Florida Attorney General, who must adopt rules to do so.

An operator must first be given 30 days to try to cure the alleged violation, though no right to cure will apply where a notice makes a knowing and material misrepresentation or omission to the detriment of a consumer.

The proposed legislation would allow for injunctive relief or civil penalties not to exceed $5,000 for “each violation.”  It’s not clear how the term violation will be applied: is that per incident, per consumer, per day, or per transaction?  Notably, privacy laws in California, Illinois, and other jurisdictions suffer from this same lack of clarity.  The Sedona Conference’s Working Group on Privacy and Data Security Liability is working on a commentary that will hopefully provide guidance on this issue.

What Is The Likelihood The Proposed Amendments Will Become Law?

The fact that SB 1670 and HB 963 are decidedly less comprehensive than the CCPA was likely a strategic decision: a CCPA-like law would have little chance of becoming law in Florida, given the current composition of the Legislature and Governor’s seat.  Nevertheless, the idea of giving Florida residents more control and notice over their online personal data, and limiting the barrage of unsolicited calls, texts, emails, and mail, will appeal to most Floridians.

Some businesses may push back against the legislation, and the degree to which there is pushback will likely be the controlling factor over the amendments’ fate.  But the fact that these bills were introduced by Republican legislators and they lack a private right of action, means they have a much better shot of passing than the proposed biometric privacy law.

In short, there’s a good chance we could see some or all of the proposed legislation become law.  At the very least, it’s a development that should stay on your radar, particularly to the extent your business (i) uses public records as a source of information for marketing purposes and/or (ii) could be considered an “operator.”

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.

© Shook, Hardy & Bacon L.L.P. | Attorney Advertising

Written by:

Shook, Hardy & Bacon L.L.P.
Contact
more
less

Shook, Hardy & Bacon L.L.P. 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.