FTC Data Security Settlement with Auto Dealer Software Provider Goes Further than Ever Before - Provides Detailed Specifications Both for Information Security Program and Third-Party Assessments

Wilson Sonsini Goodrich & Rosati
Contact

Wilson Sonsini Goodrich & Rosati

On June 12, 2019, the Federal Trade Commission (FTC) announced it had reached a proposed settlement with LightYear Dealer Technologies, LLC (doing business as "DealerBuilt") over allegations that the automobile software provider's inadequate data security practices had resulted in a data breach in 2016.1

This consent order deserves a close read because the FTC has imposed data security obligations on DealerBuilt that go further than any previous settlement, and the FTC is likely to seek to impose these requirements in future settlements.2 Specifically, the FTC has mandated DealerBuilt to implement an information security program with more detailed specifications than appear in earlier settlements. These modifications are consistent with the FTC's recent proposed amendments to the Safeguards Rule (a rule that guides FTC implementation of the Gramm-Leach-Bliley Act (GLBA)).3 The FTC has also imposed more specific requirements with regards to third-party security assessments.

Background

DealerBuilt's 2016 security incident can be traced back to an allegedly poorly configured storage device that an employee installed in April 2015 to expand the company's capacity to store backups of customer data. According to the FTC's complaint, the device left open a port through which anyone could extract sensitive information about the company's customers and employees, including Social Security numbers, driver's license numbers, birthdates, and financial information. Security researchers discovered the vulnerability 18 months later and accessed plaintext data of 12.5 million consumers across 130 car dealerships relying on DealerBuilt software.4 DealerBuilt allegedly first learned of the vulnerability and incident when a customer complained that their customer data had become publicly available.

The FTC alleged that DealerBuilt failed to develop, implement, or maintain a written organizational information security policy, failed to implement employee training regarding safeguarding personal information, failed to conduct risk assessments or use readily available security measures to periodically monitor its systems and assets to identify data security events, failed to impose reasonable data access controls, stored consumers' personal information on its network in clear text, and failed to have a process to secure and inventory devices with access to personal information. Accordingly, the FTC levied two counts against DealerBuilt in its complaint: 1) that the company's failure to provide reasonable security to personal information belonging to its customers and employees amounted to an unfair practice under Section 5 of the FTC Act; and 2) that the company's lack of an information security program violated the FTC's Safeguards Rule under the GLBA.5

Key Takeaway #1: The Proposed Order Furthers the Recent Trend of the FTC to Provide Greater Specificity on Requisite Information Security Programs

In the past, the FTC has allowed companies a degree of flexibility in implementing reasonable security practices, including entering into settlements that left room for companies to develop controls and procedures tailored to their unique risks. In 2018, the Eleventh Circuit vacated an FTC order imposed on the medical laboratory LabMD after finding the order to be unenforceable because it "does not enjoin a specific act or practice. Instead, it mandates a complete overhaul of LabMD's data-security program and says precious little about how this is to be accomplished."6 In our June 2018 WSGR Alert regarding the U.S. Court of Appeals for the Eleventh Circuit's decision in LabMD v. FTC, we anticipated that the FTC might respond to the decision by enjoining specific acts or practices in future security and privacy orders. The DealerBuilt settlement, along with two similar but somewhat less specific data security settlements announced in April of this year,7 suggests this day has arrived.

Specifically, the DealerBuilt settlement demonstrates the FTC is moving in the direction of providing more detailed specifications for how companies should implement information security programs both under Section 5 of the FTC Act and the FTC's Safeguards Rule under the GLBA. Commissioners and stakeholders have been split on the issue of specificity in recent years, and when the FTC issued a notice of proposed rulemaking (NPRM) in April 2019 to amend the Safeguards Rule to include more specific requirements for information security programs, it reopened this debate. Proponents of increased specifications point to the benefits of having more "guidance and certainty" in designing information security programs.8 On the other side, opponents argue that too much prescription removes the flexibility needed to design industry-specific solutions.9 While the FTC voted 3-2 to publish the Safeguards Rule NPRM in March 2019, Commissioners Noah Phillips and Christine Wilson released a dissenting statement expressing concern that adding more specifications "trades flexibility for a more prescriptive approach" and tries to answer questions "firms are in a better position to evaluate than federal regulators."10 The FTC vote to issue the proposed administrative complaint and to accept the consent agreement with DealerBuilt, however, was a unanimous 5-0.

In the meantime, in its settlement with DealerBuilt, the FTC has pulled from proposed amendments to the Safeguards Rule in its NPRM and has gone further than ever before in specifying particular controls DealerBuilt must implement in its information security program. Below is a list of specifications imposed on DealerBuilt that the FTC appears to have taken from the still-pending Safeguards Rule NPRM:

  • Providing a written copy of the information security program and annual updates to the board of directors or governing body.
  • Encrypting all Social Security numbers and financial account information.
  • Establishing policies and procedures to ensure devices with access to Personal Information are securely installed and inventoried at least once per year.
  • Implementing data access controls for all databases storing Personal Information.
  • Conducting vulnerability testing of the network at least every four months and penetration testing at least once per year.

The DealerBuilt settlement builds on more specific obligations that were first required in two data security settlements that the FTC announced in April 2019.11 Unlike prior FTC data security consent orders, the DealerBuilt and April 2019 orders mandate that, at least once every 12 months and promptly following certain incidents affecting consumer information, businesses are required to perform security risk assessments and to update their safeguards and security programs. In addition, the DealerBuilt and April 2019 settlements require senior management to provide annual compliance certifications to the FTC, require the company to submit covered incident reports to the FTC within 10 days after notifying other government entities of certain incidents affecting consumer information, and prohibit the company from misrepresenting any material facts to their information security program assessor.

Businesses can expect to see similar types of specific data security requirements in FTC consent orders going forward.

Key Takeaway #2: The Proposed Order Adds New Requirements for Third-Party Assessments

The proposed order also includes never-before-seen requirements for third-party assessments that go a step further than the requirements the FTC included in the two settlements announced in April 2019.

In the April 2019 settlements, the FTC required either that the assessor be qualified via various certifications such as CISSP and CISA or that the assessor be approved by the associate director for enforcement for the bureau of consumer protection at the FTC. The DealerBuilt consent order, however, removes all guidance on recommended certifications, instead leaving it to the "sole discretion" of the associate director for enforcement at the FTC to approve the assessor chosen by the company. Additionally, the order goes further to require that the assessor:

  • State and sign that it has conducted an independent review of the information security program.
  • Identify specific evidence, including, but not limited to, documents reviewed, sampling and testing performed, and interviews conducted to make determinations.
  • Retain all documents relevant to the assessment for five years after its completion and make these materials available to the FTC within 10 days of receiving a request to do so.
  • Explain why the evidence examined is sufficient to justify the findings.
  • Not rely solely on assertions or attestations by management to come to any finding of in the assessment.
  • Not withhold documents from the FTC on the basis of a claim of confidentiality, proprietary or trade secrets, work product protection, attorney client privilege, statutory exemption, or any similar claim.

These assessor obligations are interesting because they seem to impose specific consent order obligations on an unnamed entity that is not a party to the order. In particular, the specific obligations to refrain from relying solely on assertions or attestations by management, and not to withhold documents from the FTC under established protections, may run counter to another requirement of the consent order, that the assessor use "procedures and standards generally accepted in the profession." As a result, it may be difficult for DealerBuilt and future businesses, if they agree to similar consent orders, to find competent assessors who are able to comply with these obligations imposed by the FTC.

Finally, for the first time in the DealerBuilt settlement, the FTC expressly requires the responding company to cooperate with the third-party assessor by disclosing all material facts to it, adding a new layer on top of previously seen requirements not to misrepresent any material facts to the assessor in the course of the investigation.

Conclusion

The FTC's consent order with DealerBuilt sheds light on the direction in which the agency is likely headed—towards imposing more specific information security requirements and increasing oversight of third-party assessments and the assessors themselves. The consent order provides helpful insight into the FTC's conception of "reasonable security," which may include access controls for sensitive information, device security and device inventorying, and penetration and vulnerability testing. The consent order also makes clear that the FTC will now hold companies and assessors more accountable for third-party assessments by exercising control over who qualifies as an appropriate assessor and by requesting evidence of the assessment after completion. Nevertheless, it remains to be seen how these new requirements will play out in practice as DealerBuilt—and future businesses put under similar orders—attempt to operationalize them (and in particular attempt to find appropriate assessors).

1 Press Release, FTC, Auto Dealer Software Provider Settles FTC Data Security Allegations, June 12, 2019, https://www.ftc.gov/news-events/press-releases/2019/06/auto-dealer-software-provider-settles-ftc-data-security.
2 FTC Consent Order, In the Matter of Lightyear Dealer Technologies, LLC, https://www.ftc.gov/system/files/documents/cases/172_3051_dealerbuilt_final_consent_agreement_6-12-19.pdf.
3 Notice of Proposed Rulemaking, Standards for Safeguarding Customer Information, 84 Fed. Reg. 13158 (proposed April 4, 2019) (to be codified at 16 C.F.R. pt. 314).
4 Oksana Tunikova, Car Dealership Provider Leaky CRM, MacKeeper Blog, November 8, 2016, https://mackeeper.com/blog/post/299-car-dealership-provider-leaky-crm/.
5 FTC Complaint, In the Matter of Lightyear Dealer Technologies, LLC, https://www.ftc.gov/system/files/documents/cases/172_3051_dealerbuilt_final_complaint_6-12-19.pdf.
6LabMD, Inc. v. Fed. Trade Comm'n, 894 F.3d 1221, 1237 (11th Cir. 2018).
7 Press Release, FTC, FTC Alleges Operators of Two Commercial Websites Failed to Protect Consumers' Data, April 24, 2019, https://www.ftc.gov/news-events/press-releases/2019/04/ftc-alleges-operators-two-commercial-websites-failed-protect.
8 Notice of Proposed Rulemaking, Standards for Safeguarding Customer Information, 84 Fed. Reg. 13158 (proposed April 4, 2019) (to be codified at 16 C.F.R. pt. 314).
9Id.
10 Public Statement, FTC, Dissenting Statement of Commissioner Noah Joshua Phillips and Commissioner Christine S. Wilson - Regulatory Review of Safeguards Rule, March 5, 2019, https://www.ftc.gov/public-statements/2019/03/regulatory-review-safeguards-rule-dissenting-statement-commissioner-noah.
11 See, e.g., FTC Decision and Order, In the Matter of James V. Grago, Jr., individually and d/b/a ClixSense.com, https://www.ftc.gov/system/files/documents/cases/172_3003_-_clixsense_order_final.pdf; see also United States of America v. Unixiz, Inc. et al, No. 5:19-cv-2222 (N.D. Cal. April 24, 2019).

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.

© Wilson Sonsini Goodrich & Rosati | Attorney Advertising

Written by:

Wilson Sonsini Goodrich & Rosati
Contact
more
less

Wilson Sonsini Goodrich & Rosati on:

Readers' Choice 2017
Reporters on Deadline

Related Case Law

"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.