Retailer - Fall 2014

by Constangy, Brooks, Smith & Prophete, LLP

For a printer-friendly PDF, click here.

The Express Lane

  • Retailer's Recap
  • Noteworthy Numbers
  • News and Analysis
    • Criminal Background Checks: Three Tips for Retail Employers
    • Is EEOC Bound by Statutory Limitations Period When Making Pattern-or-Practice Claims?
    • More Social Media Angst for Retailers

Fall 2014

Retailer's Recap

Counting the Cost of Payroll Cards: Are they Worth it for Employers? Retailers, as well as other employers, have grown to rely on payroll cards to compensate employees who may not have bank accounts. What are the legal risks of paying with payroll cards, and what precautions should retailer employers take? Read all about it!

NLRB takes aim at franchising relationships. The National Labor Relations Board is aggressively finding "joint employer" relationships wherever it can, and the General Counsel has issued an opinion that franchisors may be joint employers with their franchisees, a position that ought to cause concern to retail employers.

An In-Depth Look at the EEOC's New Enforcement Guidance on Pregnancy Discrimination. Do retail employers have to make reasonable accomodations for pregnancy? Maybe so.

NLRB Just Keeps Strikin' Down Those Workplace Rules. Among the latest victims are Hooters, which prohibited insubordination (the horror!) and Kroger, which had a social media policy requiring employees to post disclaimers along with anything that they said about the company. Will the NLRB let employers have any rules?

So many harassment mistakes, so little time. Retail employers make these "dirty dozen" harassment mistakes at their peril. But employees can mess up too, by not reporting the harassment or by not cooperating in the investigation.

Disability accommodation, the EEOC, and the most expensive bag of potato chips ever. Inventory shrinkage at Walgreen's and the $180,000 bag of chips.

ADA Interactive Process: A Quiz for Employers. Are you and your store managers properly handling the "interactive process" under the Americans with Disabilities Act? A lot of employers are not. Take this quiz and find out where you stand.

Grocery Workers Stage Strike – to Bring Back their CEO! If you're getting tired of bad or alarming news, here is a story that will make you all warm and fuzzy again. (And, by the way, after this was published, the CEO made a deal to buy the company, so we have a happy ending, too.)

Noteworthy Numbers

Retail Sales at a Glance

Online Pricing, Shopping Continue to Hurt Brick-and-Mortar Retail Stores

By Tam Yelling
Birmingham Office

According to a recent article in The Wall Street Journal (paid subscription may be needed to access the full article), in-store retail traffic has been declining by about 5 percent a month for the past two years, as consumers increasingly do their shopping online, or at least use mobile phones and computers to research products and find the best deals. An important byproduct of the change in shopping habits is that customers are less likely to browse in physical stores where they can be tempted to make impulse purchases.

Approximately $70 million in retail lease obligations nationwide are due to expire in 2018, and many retailers are expected to start closing stores at that time. "We're in a transformation where retailers are recognizing the Internet isn't going anywhere and to be competitive, you have to have a more compelling online presence and an efficient [physical] store base," according to a Moody's analyst quoted in the article. The article predicts that the most closings will occur in the office supply, specialty retail, and convenience store sectors.

Will these store closings result in lower retail employment, or will the physical store jobs be replaced with internet sales/customer service/order fulfillment jobs? We will see.


Percent of IT Budget Spent on Cybersecurity

Dollars Per Employee Spent on Cybersecurity


SOURCE (both charts): Rachael King, "Retail Spends Less on Cybersecurity Than Banking, Healthcare," The Wall Street Journal, Sept 2, 2014. (Paid subscription may be needed to access article.)

News and Analysis

Criminal Background Checks: Three Tips for Retail Employers

By Doris Del-Castillo
Tampa Office

Retail employers have turned to the information contained in criminal background checks to vet employment candidates. In doing so, retailers attempt to secure a safer working environment and reduce losses due to theft and other kinds of dishonesty. However, overbroad use of criminal background information has been criticized by the Equal Employment Opportunity Commission because the use of such information tends to disproportionately screen out African-American and Hispanic males. The following three tips will help retail employers keep a secure workplace without running afoul of the EEOC.

First, a criminal background check should be deferred until after a successful interview, or even later in the hiring process. Many states have "ban the box" provisions that prohibit employers from requesting criminal background information on employment applications. To be in compliance with as many states as possible, the request for criminal background information should occur as late in the hiring process as possible. And don't forget – if you use a third party to conduct your criminal background checks, you will have to comply with the Fair Credit Reporting Act, and possibly other laws.

Second, do not take a blanket approach to criminal convictions. Your policy, application forms, and other relevant paperwork should include a statement that the background check will not automatically disqualify the candidate from employment. Each conviction should be reviewed on a case-by-case basis, taking into account the type of crime that was committed, the time that has passed since the conviction, the age of the applicant when the crime was committed, and the relevance of the crime to the position being applied for, as well as other factors.

Third, retail employers should make sure that managers and supervisors are trained on the policy and the proper use of criminal background information. This is especially true in retail environments, where managers at remote locations often have to make employment decisions "on the fly" without easily accessible support from Human Resources or even their regional managers.

Is EEOC Bound by Statutory Limitations Period When Making Pattern-or-Practice Claims?

By Toby Dykes
Birmingham Office

The EEOC continues to aggressively pursue litigation, and when the EEOC files suit, retail employers can expect a costly and protracted legal battle. The agency may not even be limited by the 180-day or 300-day charge-filing period, according to a recent decision from a federal court in Minnesota.

The EEOC filed a pattern-or-practice lawsuit against PMT Corporation, alleging that the company maintained a hiring system that discriminated against female and older applicants for sales positions. Specifically, the EEOC claimed that of the 70 sales representatives PMT hired between January 1, 2007, and October 27, 2010, none were female or over the age of 40.

Because the EEOC did not file a charge until October 27, 2010, PMT argued that any hiring decisions made more than 300 days before that date were not actionable. Accordingly, PMT moved to dismiss the lawsuit, contending that the EEOC did not attempt to conciliate in good faith because it sought relief for untimely claims.

The court denied PMT's motion. Although generally the 300-day period applied in Minnesota, the court said, older alleged discriminatory acts could be considered if there was a continuing violation. And if the EEOC could prove a pattern or practice of discrimination, then it would also establish a continuing violation for timeliness purposes. Therefore, the court said, "relief for conduct outside the 300-day period is not categorically barred, and the EEOC did not act in bad faith by attempting to obtain relief for such conduct."

(Minnesota, and many other states, have fair employment practice agencies. In those states, an EEOC charge must generally be filed no later than 300 days after the last act of alleged discrimination. In states without such agencies, the deadline for filing an EEOC charge is generally 180 days after the last act of discrimination.)

Not all courts have reached the same result as the PMT court. A federal judge in Maryland found that the 300-day limitations period did apply in an EEOC pattern-or-practice suit against Freeman, which involved criminal background checks. That case is now at the U.S. Court of Appeals for the Fourth Circuit, which hears appeals from federal courts in Maryland, the Carolinas, Virginia, and West Virginia.

But back to PMT: In addition to finding that a pattern-or-practice claim could be brought for allegations outside of the statutory limitations period, the Minnesota federal court found that the lawsuit did not have to identify the alleged victims by name. Instead, the Court found that by identifying the time period of the alleged discrimination, the alleged perpetrator of the discrimination, and the alleged discriminatory conduct, the EEOC had stated its claims with sufficient particularity to survive a Motion to Dismiss.

The EEOC also filed individual claims of retaliation and constructive discharge on behalf of the Human Resources Manager who brought the alleged discrimination to light, but the court granted PMT's motion to dismiss those claims.

More Social Media Angst for Retailers

By Toby Dykes
Birmingham Office

Courts, state legislatures, and the National Labor Relations Board continue to limit employers' control over social media accounts and postings.

Under a law in New Hampshire that was signed by the governor on August 1 and became effective September 30, employers are barred in most instances from requiring employees or job applicants to provide log-in information for personal social media accounts. The law makes exceptions for employers who are investigating whether the social media account was involved in the unauthorized transfer of confidential, financial, or proprietary information, as well as investigations necessary to ensure compliance with laws, regulations, or workplace conduct rules.

Employers are prohibited from requiring that employees or applicants "friend" them or add them to lists that have access to the social media accounts. Additionally, the law prohibits employers from disciplining employees who refuse to provide access to the log-in information for personal and social media accounts.

At press time, not only New Hampshire, but also Arkansas, California, Colorado, Illinois, Maryland, Michigan, Nevada, New Jersey, New Mexico, Oklahoma, Oregon, Rhode Island, Tennessee, Utah, Washington, and Wisconsin had enacted laws limiting employers' access to the social media accounts of employees and applicants.

Meanwhile, over at the NLRB, the Board ordered that two employees of a non-union bar and restaurant be reinstated and made whole after they were terminated for a Facebook discussion lambasting their employer. In Three D, LLC, several employees learned that that they would owe more in Connecticut state income taxes than they had anticipated, and they blamed the company for failing to do proper withholding. After a spirited group discussion on Facebook, in which "F bombs" were flying, one of the two terminated employees called "Ralph" (apparently the employee who had payroll responsibilities) an "a**hole." The other terminated employee merely "liked" a comment from someone else who said she was going to complain to the labor board. The two terminated employees filed unfair labor practice charges, alleging that they were discharged for engaging in protected concerted activity. An NLRB administrative law judge agreed with them in 2012, and last month, the NLRB issued its decision, agreeing with the ALJ and the two employees.

Three D argued the two employees lost the protection of the National Labor Relations Act because they had adopted defamatory and disparaging comments. But the Board determined that the use of a single expletive (in the case of the one employee) and a "like" (in the case of the other) was not enough to result in a loss of NLRA protection. The Board also found that the comments were not "disloyal" to the company because the employees did not even mention its products or services, much less disparage them.

The two Democrat members who decided the case – Kurt Hirozawa and Nancy Schiffer – also determined that Triple D's Internet/Blogging policy violated the Act because employees would have reasonably interpreted the policy to prohibit the type of protected Facebook activity that led to the unlawful discharges. The policy that Hirozawa and Schiffer found to violate the Act prohibited "engaging in inappropriate discussions about the company, management, and/or co-workers, the employee may be violating the law and is subject to disciplinary action, up to and including termination of employment." Republican Member Phil Miscimarra dissented from this part of the decision.

Three D has now petitioned for review by the U.S. Court of Appeals for the Second Circuit, which hears appeals from federal courts in Connecticut, New York, and Vermont.

Retail employers, beware: (1) protected concerted activity claims apply to non-union, as well as unionized, employers; and (2) employers should carefully review their social media policies to make sure that they are in compliance with the law as it currently stands. Needless to say, all employers should be extremely cautious before taking action against an employee based on his or her social media activity.

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.

© Constangy, Brooks, Smith & Prophete, LLP | Attorney Advertising

Written by:

Constangy, Brooks, Smith & Prophete, LLP

Constangy, Brooks, Smith & Prophete, 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 (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

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 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 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 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

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:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (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
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit 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 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:

- 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.