"Key Takeaways: Fifth Annual Pharmaceutical and Medical Device Seminar"

On November 17, 2015, a group of Skadden attorneys and corporate counsel joined representatives from more than 20 life sciences companies to discuss U.S. enforcement issues companies throughout the industry face. The key takeaways from the panels are summarized below.

DOJ Enforcement Update

Panelists examined major settlements from the last three years and identified key trends.

They discussed how financial relationships with physicians and other health care professionals (HCPs) remain the most significant enforcement risk area for pharmaceutical and medical device companies.

  • Over the last decade, the threshold for bringing a case premised on an Anti-Kickback Statute violation has lowered, and financial relationships that may not have attracted scrutiny in years past are becoming the basis for today’s enforcement actions. For example, though the number of cases in which companies allegedly offered HCP trips to resort destinations has declined, the government has now begun to focus on the substance of a company’s speaker programs and on whether there is appropriate value to the company for the compensation that is being paid to health care providers.
  • Panelists recommended that legal and compliance teams work with their colleagues to ensure that all financial relationships with HCPs are justified through a robust assessment process. For example, it is a best practice to examine whether a particular product actually needs an expansive speaker program in light of factors such as how long the product has been on the market and whether there are any new indications, warnings or contraindications.

They also examined how executives at small pharmaceutical and medical device companies are at greater risk for individual prosecution than their counterparts at larger companies, in part because they are more likely to have engaged in substantive decision-making and communications regarding day-to-day operations and tactical approach.

Additionally, they discussed how Current Good Manufacturing Practice violations have not been a significant factor in recent False Claims Act actions, and we expect that trend to continue except in cases demonstrating significant patient harm resulted from such violations.

They also looked at how it is no longer a foregone conclusion that when a life sciences company enters into a settlement agreement the company will also be expected to enter into a Corporate Integrity Agreement (CIA). In 2014, there were 13 settlement agreements and eight of those did not result in new CIAs. To date, there have been 12 settlement agreements in 2015 and six of those resulted in no new CIA. Furthermore, although settling a case while under a current CIA can result in exclusion, that outcome is not inevitable. By the end of October 2015, four companies under pre-existing CIAs entered new settlement agreements and none of those entities were excluded.

The panelists examined how recent indictments and guilty pleas of a Warner Chilcott subsidiary — as well as several Warner Chilcott executives, employees and speakers — provide insight into the evolving federal prosecutorial approach.

  • Importantly, prosecutors are seeking and securing guilty pleas for health care fraud violations under 18 USC § 1347. This provision enables prosecution of false or misleading statements made to both public and private insurers.
  • The government also has pursued the theory that by filling out prior authorization forms, an employee (and consequently his employer) violated HIPAA by obtaining individually identifiable health information and using such information for financial gain. One Warner Chilcott charging document professed that a pharmaceutical sales representative violated HIPAA by merely viewing a patient’s medical file.

The panel also discussed the recent Genzyme settlement and deferred prosecution agreement (DPA). Unlike previous DPAs, Genzyme’s agreement with the Department of Justice and the U.S. Attorney’s Office for the Middle District of Florida includes new provisions that resemble a “mini CIA” and signal that the DOJ is beginning to try its hand at compliance monitoring.

Panelists also examined recent trends in whistleblower civil litigation. For example, relators and their counsel are demonstrating increased willingness to pursue cases even after the government has declined to intervene or has allowed the case to become unsealed. This uptick in plaintiff-led civil suits is fueled by the substantial settlements over the past decade and supported by an increasing number of former prosecutors joining the relators’ bar.

A few recent cases hint that the issue of statistical sampling of claims in FCA cases could become a major source of stress for government contractors, health care providers and other companies seeking government funding. While some courts reject the use of statistical sampling to establish any element of a case, others limit its application to determination of damages. But in one 2014 Eastern District of Tennessee case, the court allowed the use of statistical sampling to establish liability, knowledge and materiality.

Prosecution of Individuals: New DOJ Memo and Recent Developments

On September 9, 2015, the DOJ issued a memorandum titled “Individual Accountability for Corporate Wrongdoing” (often referred to as the Yates memo).1 The memorandum outlines six “required” steps to “strengthen” government efforts to hold individuals accountable for corporate wrongdoing. Panelists discussed the steps most likely to have a new effect on life sciences companies.

The first, and most widely discussed step from the Yates memo, instructs that to be eligible for any cooperation credit, a corporation must investigate and disclose all relevant facts and identify all individuals involved in the corporate misconduct. Panelists noted that this policy presumes the occurrence of the alleged wrongdoing and may preclude cooperation credit for investigations that do not reveal evidence of culpable conduct.

It also adds complexity from the start of even seemingly minor investigations because in order to gain any cooperation credit, companies must maintain flexibility to make any government-requested disclosures. Companies will need to consider retaining outside company counsel and individual employee counsel earlier, and ensure careful Upjohn warnings throughout to maintain their sole discretion to disclose information learned. Companies also may decide to involve their boards in investigations much sooner, especially if there is a possibility that executives or other senior management were involved in or were aware of the alleged misconduct.

Although the DOJ insists that a company can earn credit by disclosing just the underlying facts without waiving privilege, panelists agreed that this might prove difficult to implement because disentangling privileged communications from nonprivileged underlying facts can be challenging. Panelists questioned the true value of “cooperation credit” when many companies investigated in recent decades did not appear to realize meaningful benefits in exchange for their cooperation.

The second step requires both criminal and civil corporate investigations to focus on individuals from the inception of the investigation. Panelists debated whether this was a real policy shift or just a political gesture codifying long-standing practices. They noted that the Warner Chilcott, HDL and Acclarent prosecutions of individuals all predate the Yates memo. Whatever the official policy, in recent years the government’s focus on corporate liability likely is because such cases promise higher financial recoveries and the government’s exclusion power provides greater settlement leverage against corporations. The government also might have avoided criminal cases against individuals because they are more difficult to prove. If pushed to hold more individuals accountable, the government may elect to pursue misdemeanor prosecutions under the Federal Food, Drug, and Cosmetic Act and other strict liability statutes that demand only a “preponderance of the evidence.”

The third through fifth steps in the Yates memo require cooperation across criminal and civil investigations, prohibit corporate resolutions that provide individuals with protection from criminal or civil liability, and direct federal prosecutors to resolve corporate cases only after establishing a clear plan to resolve related individual cases. The fifth step also requires that any declinations as to individuals should be memorialized and approved. Panelists agreed that these steps could prolong many investigations and obstruct efforts to achieve a “global peace.”

While the first step incentivizes higher-level executives to produce evidence implicating lower-level employees, steps three through five create a counter pressure to encourage lower-level employees to incriminate the company and its executives. In many cases, these lower-level employees might possess the evidence the government needs to establish the most difficult elements of its case (e.g., intent).

The last step described in the Yates memo instructs civil attorneys to evaluate whether to bring suit against an individual based on considerations beyond that individual’s ability to pay. While some might applaud an effort to empower assistant United States attorneys to pursue cases against guilty individuals that might otherwise escape accountability, panelists questioned whether this policy will encourage wasteful investment of government resources to pursue cases without hope of commensurate financial recovery.

State Attorney General Enforcement Actions and Defense Strategies

Investigations initiated by state attorneys general (AGs) are similar to federal investigations in many ways, but there are some notable differences that may influence a company’s litigation strategy.

Panelists agreed that state AGs are often more likely than their federal counterparts to be influenced by and beholden to politics and the media. Panelists expressed the opinion that many state AGs have political aspirations and may use their investigation of a company as a platform to highlight their political ideologies.

State consumer protection and Medicaid fraud statutes are generally broader and more prosecution-friendly than similar federal statutes. These provisions, therefore, are rarely challenged, leaving little case law to help defendants develop a litigation strategy in a potentially unfriendly forum.

Panelists provided practical tips for document and data production:

  • Regardless of who is conducting the investigation, it is important to build rapport with your investigator. The investigator may be able to tell you whether he has heard a detailed account of the facts from other prosecutors or whistleblowers.
  • State AGs are likely to make sweeping and overly broad document and data requests. Panelists suggested that companies make an early effort to narrow the scope of the requests and productions by time, geography, relevant personnel and tailored search terms.
  • If the state investigation is trailing a federal investigation, consider whether to offer to produce relevant information that already has been provided to the federal government or other state investigators. State AGs may have limited resources to review your productions and therefore may be flexible with their requests and open to negotiation.
  • Not all states offer privacy and data protection for materials produced in the course of an investigation. Before providing materials to the AG, panelists encouraged counsel to review state statutes and append state-specific protective language to each production.

When multiple state and federal investigations arise, companies should explore opportunities to reduce the risk that other states will join:

  • Although unlikely to halt all interested investigators, proactive outreach to states that have not yet initiated a formal investigation may help them decide not to pursue action or to limit the scope of their investigations. When presenting your case to a state AG, be thoughtful about ways to explain what went wrong; present evidence of the company’s efforts to comply during the same time period; explain changes in policy, controls, culture or personnel in the period following the relevant timeframe; and demonstrate the company’s effort to redress or mitigate harm.
  • Develop strategies for dealing with states. In some cases it may be best to engage in individual, rather than collective, communications regarding an approach to the investigation. Such a strategy is advisable when states seem to disagree regarding the necessary scope, depth, timeline and anticipated outcome of the investigation.
  • Some states prefer to settle, so it may be possible to engage in early, straightforward discussion of settlement terms.

Panelists also emphasized that companies should be cautious and thoughtful about negotiating settlement terms and injunctive relief. Injunctions, in particular, can cause long-term competitive harm; accordingly, it is important to negotiate a firm sunset provision on settlement terms to ensure that prohibitions on product development, promotion, marketing or distribution are not indefinitely deferred.

The terms in early settlement agreements may influence what terms are proposed in later negotiations with other states. Additionally, many companies are not in a position to have different business practices in each of the 50 states. Panelists suggested that before entering an agreement with one state, consider whether the company would be willing to accept the terms of the proposed agreement if they applied nationwide.

1 Memorandum from Sally Quillian Yates on Individual Accountability for Corporate Wrong Doing (Department of Justice Sept. 9, 2015), available at http://www.justice.gov/dag/file/769036/download.

Download PDF

 

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.

© Skadden, Arps, Slate, Meagher & Flom LLP | Attorney Advertising

Written by:

Skadden, Arps, Slate, Meagher & Flom LLP
Contact
more
less

Skadden, Arps, Slate, Meagher & Flom LLP 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.