The Chronicle: American Adult-Use Marijuana Laws - Regulator

Carlton Fields
Contact

Carlton Fields

This category includes provisions related to the creation or designation of a regulatory body to oversee the adult-use marijuana industry and the regulator's powers. Statutory provisions related to the following topics are included:

  • Tracking requirements
  • Record-keeping requirements
  • Identification card requirements
  • The regulator's power to impose fines on licensees and suspend or revoke licenses
  • The regulator's power to seize or order the destruction of marijuana
  • Reports that the regulator or a related administrative body are required to issue

Common Provisions

Regulatory body

Alaska, California, Massachusetts, Nevada, and Washington created new regulatory agencies to oversee regulation of adult-use marijuana. The remaining states delegated regulatory authority over adult-use marijuana to one or more preexisting state agencies. Washington, D.C., has not designated a regulatory authority with regard to marijuana.

Every state that has created a regulator has given it rulemaking authority.

All states that permit the retail sale of marijuana (Vermont and Washington, D.C., do not) authorize the regulator to examine the books of a licensee as well as the licensed premises.

Caps on the number of licenses

The states have taken widely divergent approaches to this issue. California, Colorado, and Washington require the regulator to establish limits on the number of licenses. Nevada empowers the regulator to adopt "policies and procedures to ensure that the cannabis industry in this State is economically competitive," which could conceivably include limitations on the number of certain types of licenses.

Illinois establishes initial statutory limits on the number of each type of license that may be issued, and thereafter permits the regulator to issue additional licenses, up to a statutorily prescribed limit, after consideration of a number of statutorily provided factors.

Maine and Michigan expressly prohibit the regulator from imposing a limitation on the number of any type of license that may be issued.

Qualifications for licensure

All licensing states,[1] except Maine, permit the regulator to adopt qualifications or requirements that licensees must meet in order to be licensed. Maine statutorily provides all the criteria that an applicant must meet and permits the regulator to consider certain additional statutorily provided information in determining whether to issue an applicant a license. Alaska and Michigan expressly require such regulatory qualifications to be "directly and demonstrably related to the operation of a marijuana establishment."

Discipline, suspension, and revocation of licenses

All licensing states empower the regulator to discipline a licensee for failure to comply with state laws or regulations, including the power to suspend or revoke a license.

California, Colorado, Illinois, Oregon, and Washington provide statutory grounds for suspension or revocation of a license. The other states either require or permit the regulator to establish grounds for suspension or revocation by rule.

Marijuana tracking requirements

All licensing states, except Alaska, either require the regulator to adopt marijuana seed-to-sale tracking requirements or statutorily impose such requirements. Some states require the regulator to establish a tracking program that licensees must participate in, while others require the regulator to establish certain requirements with which a licensee's tracking program must comply and rely on the licensee to implement a compliant tracking system.

Record-keeping requirements

All licensing states, except Alaska and Washington, either statutorily require licensees to keep certain records or require the regulator to promulgate regulations requiring licensees to keep certain records. Alaska does not address the issue, although it does empower the regulator to examine any records that licensees do keep. Washington empowers the regulator to issue regulations regarding record-keeping requirements, but it does not require it to do so.

Licensee identification cards

Colorado, Illinois, Maine, and Nevada require the regulator to issue identification cards to licensees and their employees. Massachusetts requires the regulator to issue a registration card for each "laboratory agent." Oregon requires any individual who performs work for a marijuana licensee to have a "marijuana handler" permit.

Illinois provides specific identification cards for dispensing organization agents, cultivation center agents, craft grower agents, processing organization agents, transporting organization agents, infuser organization agents, and "community college cannabis vocational training pilot program faculty participant agents."

Safe disposal of excess or contaminated marijuana

Six states statutorily regulate the disposal of excess or contaminated marijuana. California empowers the state's Department of Public Health to "embargo" marijuana if it finds it has been adulterated or misbranded.

California, Colorado, and Maine authorize the regulator to destroy a marijuana product after either a hearing or the issuance of a final order by the regulator.

Illinois provides the most detailed requirements related to destruction and disposal of marijuana. The state requires dispensary licensees to submit detailed written policies and procedures for destruction of any recalled marijuana product as well as the segregation and destruction of "outdated, damaged, deteriorated, misbranded, or adulterated cannabis." Illinois requires marijuana and marijuana-infused products to be destroyed "by rendering them unusable using methods approved by [the regulator]." It also requires testing labs to "immediately return or dispose of any cannabis upon the completion of any testing, use, or research." Finally, "all cannabis byproduct, scrap, and harvested cannabis not intended for distribution to a dispensing organization must be destroyed and disposed of under rules adopted by the Department of Agriculture."

Seizure of noncompliant marijuana by the regulator

California, Colorado, Illinois, Maine, Massachusetts, Oregon, and Washington authorize the regulator to seize marijuana that is not in compliance with the requirements of the law. The seized marijuana typically may not be destroyed until after a hearing has been held or other procedural requirements have been met.

Michigan and Vermont provide for the forfeiture of marijuana involved in the commission of a crime, but do not specifically address seizure by the regulator.

Alaska and Nevada do not provide any authority for the regulator to seize noncompliant marijuana in the possession of licensees, although law enforcement authorities could presumably do so.

Colorado, Maine, Nevada, and Oregon explicitly provide that localities and state agencies are not required to care for seized marijuana plants.

Annual meeting and annual report requirements imposed on the regulator or an advisory body

Alaska, Michigan, and Oregon require the regulator to hold at least one public meeting annually.

Illinois and Maine require an advisory body to the regulator to hold at least one annual public meeting.

All states except Alaska and Washington, D.C., require the creation of an annual report by either the regulator or an advisory body and with regard to the marijuana market and the implementation of the marijuana laws.

Regulator board members and employees restricted from participation in the marijuana industry

All licensing states except Massachusetts and Oregon impose restrictions or prohibitions on persons having a financial interest in the marijuana industry from either being a member of the board or an employee of the regulator.

Uncommon and Unique Provisions

Death or insolvency of a licensee

Colorado, Illinois, and Oregon provide procedures for the handling of a marijuana license upon the death or bankruptcy of a licensee, although each state takes a different approach to the issue.

Environmental requirements

Five states have enacted some form of environmentally related requirement or restriction on marijuana licensees. California requires state agencies to "address" the environmental impacts of marijuana cultivation and to coordinate with cities and counties in enforcement efforts. It also permits the regulator to adopt energy and environmental standards applicable to marijuana licensees, and permits local governments to adopt additional standards, requirements, or regulations.

Illinois requires license applicants to submit a detailed "environment plan" as part of their license application, including information regarding how the licensee will address energy needs, estimates of energy and water usage, water filtration plans, and whether the licensee has or will adopt a waste reduction policy.

Maine requires cultivation licensees to submit an operating plan that provides for wastewater and waste disposal, as well as how the licensee will comply with applicable federal and state environmental requirements. Oregon permits the regulator to adopt merit-based criteria for licensure that may include "implementation of best environmental practices." Oregon also requires cultivators to submit a report in conjunction with a license renewal application that describes the licensee's electrical and water usage.

Revocation of "inactive" licenses

Colorado and Maine authorize the regulator to revoke an "inactive" license.

Oregon authorizes the regulator to revoke a license for "any other reason that, in the opinion of the [regulator], based on public convenience or necessity, warrants revoking" the license.

Washington requires the regulator to adopt rules establishing a process for forfeiture of a retailer license when the retailer is not fully operational and open to the public within a specified period of time from the date the license was issued. That period of time may not be less than nine months or more than 24 months, provided that the regulator may not revoke the license if it determines that the licensee has not begun operations due to circumstances out of its control, such as the imposition of a moratorium on marijuana establishments by the local government where the licensed facility would be situated.

Promotion of small businesses, "craft growers," or microbusinesses

Nevada requires the regulator to "establish a pilot program for identifying opportunities for an emerging small cannabis business to participate in the cannabis industry."

Massachusetts requires the regulator to adopt regulations "to promote and encourage full participation in the regulated marijuana industry by farmers and businesses of all sizes," which must include the creation of a schedule of cultivator license fees "to create a craft marijuana cultivator cooperative system."

Illinois provides for the issuance of "craft grower" licenses, which are limited to 5,000 square feet of canopy space "for plants in the flowering state."

Storage of marijuana

Colorado and Maine require the regulator to adopt regulations relating to the storage of marijuana. Illinois requires license applications to include information regarding the applicant's plans for storage of marijuana and requires dispensing organizations to comply with the regulator's rules for storage of marijuana. Michigan authorizes the regulator to provide for a license type that only permits the licensee to store marijuana, but does not require the regulator to do so.

Power to fix prices for retail marijuana

Colorado expressly prohibits the regulator from fixing the price of retail marijuana. No other state addresses this issue.

Notification requirement prior to termination of licensed establishment

Colorado and Maine require a licensee to notify the regulator prior to termination of operations under a license and to forfeit all marijuana products to the regulator for destruction. Illinois also requires the licensee to notify the regulator prior to termination, but requires the licensee to "work with the Department to develop a closure plan that addresses, at a minimum, the transfer of business records, transfer of cannabis products, and anything else the Department finds necessary."

Best practices advisements issued by regulator

Massachusetts requires the regulator to issue advisory guidelines on best practices for cultivation of marijuana within a person's primary residence.

California requires the regulator to convene an advisory committee to advise licensing authorities regarding standards, regulations, and best practices and guidelines to protect public health and safety. The advisory committee is required to publish an annual report regarding its recommendations.

Washington permits licensees to apply to the regulator for advice and consultation on compliance with the law.

Board members of the regulator prohibited from holding other government positions

Alaska, Massachusetts, Nevada, and Washington prohibit board members of the regulator from holding any other state or federal office, regardless of whether that office is elected or appointed.

[1] All the states that have legalized the use of adult-use marijuana, except Vermont and Washington, D.C., provide for the licensing of various entities involved in the adult-use marijuana industry, including retailers, cultivators, testing laboratories, and so on. This article uses the term "licensing states" to refer only to those states that provide for a licensing scheme. The term does not include Vermont and Washington, D.C.

See Regulator Chart Here.

  • Illinois – All citations are to Chapter 410, Act 705 (Cannabis Regulation and Tax Act)
  • Maine – All citations are to Title 28-B (Adult Use Marijuana)
  • Massachusetts – All citations are to Title XV, Chapter 94G (Regulation of the Use and Distribution of Marijuana Not Medically Prescribed)
  • Nevada – All citations are to laws set to take effect on July 1, 2020, per 2019 Nevada Laws Chapter 595 (A.B. 533)
  • Vermont – All citations are to Title 18 (Health), except the citation to section 17 of Act 86 (2018)

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.

© Carlton Fields | Attorney Advertising

Written by:

Carlton Fields
Contact
more
less

Carlton Fields 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.