Overview of California’s Final Autonomous Vehicle Testing and Deployment Regulations – Fully Driverless Vehicles Permitted

by Akin Gump Strauss Hauer & Feld LLP
Contact

Akin Gump Strauss Hauer & Feld LLP

Key Points

  • California’s new regulations lay out the requirements for manufacturers to obtain permits to test and deploy autonomous-vehicles on public roads. The regulations enable manufacturers to test fully driverless vehicles and authorize the California DMV to issue driverless-testing and deployment permits as of April 2, 2018.
  • The Regulations eliminate provisions included in earlier drafts that limited manufacturer liability under certain circumstances (detailed in our prior alert). To qualify for testing or deployment permits, however, manufacturers must provide proof of ability to meet $5 million in potential damages.
  • Included in the Regulations are some of the first rules in the Nation to address the collection of personal information by autonomous vehicles, as well as a requirement that vehicles meet applicable and appropriate industry standards for cybersecurity.

I. Introduction

On February 26, 2018, California's Office of Administrative Law (OAL) approved final regulations for the testing and deployment of autonomous vehicles. We reported on the regulations in a prior alert. Already home to large autonomous vehicle testing facilities and key players in the industry, the new regulations may spur further development within California and could be a model for other states moving forward.

The regulations address (1) the testing of autonomous vehicles; and (2) the deployment of autonomous vehicles. The Regulations, among other things, permit fully driverless testing of autonomous vehicles on California roadways. The DMV has already issued testing permits for manufacturers using test drivers. On April 2, the Department of Motorvehicles (DMV) can begin issuing permits for driverless testing and for deployment of autonomous vehicles.

The new Regulations mark a dramatic change in California’s stance toward autonomous vehicles when compared to the state’s actions just a few years ago. In 2015, California regulators signaled that they might seek to supplant National Highway Traffic Safety Administration (NHTSA) leadership in this area by imposing strict controls on the testing of autonomous vehicles within the state. The California DMV initially proposed regulations that included restrictive requirements like mandating that all testing be carried out by independent third parties. This all began to change in 2016, after NHTSA issued its own guidelines. In September 2016, the California DMV issued revised draft deployment regulations, which were followed in March 2017 by proposed regulations to establish a path for both testing and deployment of autonomous vehicles. Those proposed rules shied away from many of the strict principles originally included just a couple years before. The March 2017 regulations set off a wave of public comments and revision that ultimately culminated in the final Regulations.     

The final Regulations recognize the preeminence of federal safety standards with regard to motor-vehicle safety on a broad scale. Under the Regulations, manufacturers must certify that their autonomous vehicles comply with all applicable Federal Motor Vehicle Safety Standards, or provide evidence of NHTSA exemption. In the deployment context, manufacturers also must certify that their autonomous technology meets standards for the vehicles’ model year and does not make any federal safety standards inoperative, and that they have registered with NHTSA.

California’s move to embrace driverless testing may be a signal of the state’s desire to keep innovation in the field within its borders. States like Arizona have wooed companies with a more hands-off approach to regulation. Waymo, for example, began testing driverless autonomous vehicles on Arizona roads in October. There are also indications that some companies that began testing autonomous vehicles in California in 2016 moved their testing operations to other states in 2017 (e.g., Ford, Tesla).

II. Overview of Key Provisions in the Regulations

The restrictions in the Regulations apply to manufacturers of autonomous technology, which include both vehicle manufacturers that produce new autonomous vehicles and those who modify vehicles by installing autonomous technology. The Regulations apply to passenger vehicles and not to camp trailers, motorcycles, vehicles weighing more than 10,001 pounds, tour buses or vehicles transporting hazardous materials. CCR 227.28.

The DMV changed or deleted various sections between earlier drafts and the final version of the Regulations. Former Section 228.28, present in the October 2017 draft, but deleted from the final Regulations, would have relieved manufacturers of liability if their autonomous technology was modified in a manner not authorized by the manufacturer or if the vehicle was not properly maintained. Liability is addressed to some extent through requirements that manufacturers provide proof of their ability to pay damages up to $5 million resulting from the operation of autonomous vehicles on public roads, through either evidence of insurance, a surety bond or a certificate of self-insurance. CCR 227.04(c); 228.04. Elimination of the former Section 228.28, however, means that courts will address liability on a case-by-case basis, unless the legislature steps in and provides clarity.

Autonomous vehicles, particularly driverless vehicles, pose a special challenge to law enforcement and first responders. The Regulations recognize this challenge by requiring manufacturers to prepare a law enforcement interaction plan that details, among other things, how law enforcement and first responders should interact with the vehicle and how the vehicle will report who it belongs to and who is operating the vehicle. The plans must be updated on at least an annual basis. CCR 227.38(e); 228.06(c)(3). This aspect of the Regulations seeks to drive practical solutions for what exactly will occur when first responders find a crashed autonomous vehicle and need to know, for example, how to move the vehicle.

The Regulations include some of the first explicit restrictions on the collection and use of personal information in the autonomous-vehicle context. “Personal information” is defined as the “information that the autonomous vehicle collects, generates, records, or stores in an electronic form that is retrieved from the vehicles, that is not necessary for the safe operation of the vehicle, and that is linked or reasonably capable of being linked to the vehicle’s registered owner or lessee or passengers using the vehicle for transportation services.” CCR 227.02(l). In the testing context, a manufacturer must disclose to passengers what personal information may be collected and how it will be used. CCR 227.38(h). In the deployment context, a manufacturer has the option to either provide a written disclosure to the driver or passengers, or anonymize the personal information. CCR 228.24(a).1  It remains to be seen exactly what kind of information will be classified as “personal information.”

III. Permit Application Requirements

A. Requirements for Testing Permits

There are four major prerequisites to testing autonomous vehicles on California roads: (1) the manufacturer must conduct the testing; (2) the vehicle must be operated by a competent and licensed test driver or remote controller who is an employee, contractor or designee of the manufacturer; (3) the manufacturer must provide the DMV with proof of its ability to satisfy judgments for potential damages in the amount of $5 million; and (4) the manufacturer must have a general or driverless testing permit. CCR 227.04. We include an overview of some of the driverless permit requirements here, given the importance of the issue:

  • Conducted Pre-Permit Testing – The vehicles have been tested under controlled conditions that simulate each operational design domain in which the vehicles will be operated and have been reasonably determined to be safe.
  • Notify Local Authorities – Manufacturers must notify authorities where the vehicles will be tested of the operational design domains of the vehicles, the public roads where the vehicles will be tested, the date that testing will begin and when it will be conducted, the number and type of vehicles that will be tested, and the contact information for the testers.
  • Two-Way Communication Link with Remote Operator – Driverless vehicles must be equipped with two-way communication links that provide the remote operator with general information on the vehicle and enables communication between the passengers and the remote operator in the event that there are any issues with the autonomous technology.
  • Process to Communicate Vehicle Information to Observer – There must be a way to display information on the vehicle in the event that there is a collision or it is needed by law enforcement.
  • Comply with Federal Standards or Exemption – The vehicle must comply with relevant federal motor vehicle standards, or it must have an NHTSA exemption.
  • SAE Level 4 or 5 and No Driver Needed – The vehicle must have capabilities that meet the description of an SAE level 4 or 5 automated driving system, with no driver present.
  • Remote-Operator Training – All remote operators must be licensed to operate the type of vehicle at issue and must complete specialized training provided by the manufacturer.  
  • Notification of Personal Information Collection and Use – Passengers must be notified of what personal information is collected from them and how it will be used.
  • Collect Autonomous System Disengagement Data – Manufacturers must collect data on the disengagement of autonomous technology (i.e., the failure of autonomous technology or a need for the remote operator to take control) and submit that data in an annual report.
  • Notify DMV Within 10 Days of Collision – Manufacturers must notify the DMV within 10 days of any collision caused by their vehicles if the collision causes damage, injury or death.
  • Cannot Charge Passengers a Fee – Manufacturers may not charge passengers a fee, nor receive any type of compensation, in exchange for rides in test vehicles.

B. Requirements for Deployment Permits

The requirements to obtain a deployment permit are more onerous than a driverless permit. We provide an overview of some of the key deployment-permit requirements below:

  • Autonomous Operation Parameters – The vehicles must not be able to operate in autonomous mode outside of the specific operational design domains disclosed in the application. Manufacturers must identify any conditions (e.g., fog, wet roads) under which their vehicles are either designed to be incapable of operating or unable to operate reliably.
  • Equipped with Autonomous-Technology Data Recorder – Vehicles must be equipped with a data recorder that captures and stores sensor data for all vehicle functions that are controlled by autonomous technology at least 30 seconds before a collision that occurs in autonomous mode. The data must be in read-only format and be retrievable through commercial means.
  • Compliance with Federal Standards or Exemption – Vehicles must comply with relevant federal safety standards (or have an NHTSA exemption) and with any standards for their respective model year. Manufacturers must register with NHTSA.
  • Designed to Comply with California Vehicle Code and Local Regulations – Autonomous technology must be designed to detect and respond to roadway situations in a manner compliant with the California Vehicle Code and applicable local regulations.  
  • Must Update Autonomous Technology – Manufacturers must update autonomous technology as needed, and at least annually, to ensure compliance with California and local vehicle regulations. They must also make available on a continual basis consistent with changes updates regarding location and mapping information utilized by a vehicle’s autonomous technology. Registered owners must be told how to update their systems.
  • Must Meet Industry Cybersecurity Best Practices – Vehicles must meet appropriate and applicable current industry standards to help defend against, detect and respond to cyber-attacks, unauthorized intrusions or false vehicle control commands.
  • Must Conduct Testing and Be Satisfied Safe – Manufacturers must conduct tests and be satisfied from the results that their vehicles are safe for deployment. A summary of such testing must be attached to the permit application and describe testing locations, among other things.
  • Two-Way Communication Link with Remote Operator for Driverless Vehicles – Driverless vehicles must be equipped with two-way communication links, as required of test vehicles.
  • Must Comply with California Vehicle Code Section 38750(c)(1) – Manufacturers must comply with California Vehicle Code Section 38750(c)(1), which requires them to certify that their autonomous technology, among other things, includes a series of safeguards (e.g., an alert when a failure is detected), is easily accessible and has a separate data recorder.
  • Safety-Related Defects Must Be Disclosed – Manufacturers must disclose to the DMV any identified safety-related defects in their autonomous technology that creates an unreasonable risk of safety in compliance with related federal timelines and requirements.
  • Provide Consumer or End-User Education Plan – Manufacturers must provide a consumer or end-user education plan for all vehicles sold or leased by someone other than themselves.
  • Describe How to Meet SAE Level 3-5 Requirements – Manufacturers must describe how a SAE Level 3-5 vehicle will safely come to a complete stop when there is a technology failure.

IV.  Potential Import of New Regulations

California’s passage of the final Regulations is likely to usher in an exciting period of innovation within the state and may spur the movement of autonomous vehicles into the everyday. It remains to be seen how courts will interpret these regulations once lawsuits are filed after these vehicles are inevitably involved in accidents. We will continue to monitor these issues and provide periodic updates.


1 If the vehicle is sold or leased, and data is not anonymized, a manufacturer must obtain the written approval of the registered owner or lessee of the vehicle.  CCR 228.24(b).  This may enable fleet operators to authorize the collection of personal information in their fleets after providing only a disclaimer to passengers.

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.

© Akin Gump Strauss Hauer & Feld LLP | Attorney Advertising

Written by:

Akin Gump Strauss Hauer & Feld LLP
Contact
more
less

Akin Gump Strauss Hauer & Feld LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.