The Significance to Businesses of the California Legislature’s Last-Minute Revisions to the 2018 California Consumer Privacy Act

Akin Gump Strauss Hauer & Feld LLP

[co-author: Tylor Dominguez, Practice Attorney]

Key Points

  • The California Legislature passed SB 1121 to revise certain sections of the CCPA – the nation’s strictest privacy protection statute which provides Californians with a right to learn what personal information certain businesses collect about them, to stop the sale of their personal information to third parties and to sue over data breaches if companies fail to adequately protect their information. The Governor has until September 30 to sign the bill.
  • Key changes in SB 1121 include (1) extending the deadline for the AGO to publish CCPA-related regulations to July 1, 2020; (2) changing the date that the AGO can begin enforcing the CCPA to the earlier of either six months from the date that the AGO publishes its CCPA-related regulations or July 1, 2020; (3) making the statewide preemption provision effective immediately to avoid the potential effects of similar measures passed by counties or cities; (4) revising the provision exempting information covered by the GLBA; and (5) clarifying and expanding exemptions relating to medical information.
  • The AGO, business groups and privacy activists may continue to press for additional revisions to the CCPA when the Legislature returns in December. It remains to be seen whether those efforts will take place or be successful and whether, and how, the CCPA may be amended further before it goes into force on January 1, 2020.

I. Introduction

The California Consumer Privacy Act (CCPA), the nation’s broadest privacy protection statute, was enacted by the California Legislature in June 2018 as part of a last-minute deal to stop a proposed statewide ballot measure that could have ushered in an even stricter privacy law. We have written about the CCPA’s passage in earlier alerts.

Sponsored by San Francisco real estate magnate Alastair Mctaggart and privacy advocacy groups, the ballot measure was strongly opposed by business groups and tech interests. Racing to beat a statutory deadline for the Mctaggart measure to be placed on the ballot, the Legislature hastily passed the CCPA in June while promising to introduce cleanup legislation after the summer recess.

Efforts to substantively revise the CCPA began nearly immediately after its passage, with the AGO (the chief enforcement agency for the CCPA), business groups, and privacy activists pressing for focused changes. Those efforts coalesced around Senate Bill 1121 (SB 1121) in August.

At the beginning of August, Sen. Bill Dodd (D-Napa) amended SB 1121 to correct various technical and drafting errors contained in the CCPA (AB 375 Chapter  XX Statutes of 2018). After intense lobbying from business groups, banks, tech interests and California Attorney General Xavier Becerra, additional substantive amendments were adopted.

On August 22, Attorney General Becerra sent a letter to the co-authors of the CCPA outlining five key complaints that he had with the CCPA and asking for corresponding revisions to the CCPA. (X. Becerra Ltr. (Aug. 22, 2018.)  Becerra opined that (1) businesses’ and third parties’ rights to seek Attorney General Office (AGO) opinions as to CCPA compliance issues would unduly burden the AGO and could lead to a conflict with its enforcement role; (2) the civil penalties included in the CCPA are likely unconstitutional, since they purport to amend and modify the California Unfair Competition Law’s (Cal. Bus. and Prof. Code §§ et seq.) civil penalty provision as applied to CCPA violations; (3) consumers should not have to provide notice to the AGO prior to filing and pursuing their private rights of action related to data breaches; (4) the AGO needs additional time and resources to draft CCPA regulations; and (5) consumers should be able to bring a private right of action for any violation of the CCPA, not only for violations tied to a data breach.

Various business groups also lobbied for substantive changes to the CCPA, including (1) adding a defense to consumers’ private rights of action where a business implemented an information security framework and documented its compliance with the same; (2) expanding the Gramm-Leech Bliley Act (GLBA) exemption; (3) expanding the exemption relating to medical information to cover business associates; (4) narrowing the definition of “personal information” to apply to information linked or linkable to a specific individual and excluding household information; (5) extending the compliance deadline to 12 months after the AGO enacts its final CCPA-related regulations; (6) ensuring that the statewide preemption goes into effect immediately; and (7) clarifying the definition of “consumer” to exclude employees, contractors and those involved in business-to-business interactions.

On August 31, SB 1121 passed both houses of the California Legislature. (SB 1121)  The Governor now has until September 30 to sign it into law. We detail the key substantive changes included in SB 1121 below.

II. Overview of Changes to CCPA in SB 1121

The revisions included in SB 1121 fall into two categories: (1) technical or grammatical revisions adopted to fix drafting errors, revise internal inconsistencies, etc.; and (2) substantive revisions that change the enforcement of the CCPA itself. This alert will focus on the latter category. SB 1121 makes the following important changes to the CCPA:

  • Extends Time for the AGO to Adopt Regulations (Section 1798.185(a)): The deadline by which the AGO has to adopt CCPA-related regulations was extended by six months from January 1 to July 1, 2020. Attorney General Becerra requested additional time to draft and pass regulations in his August 22 letter.
  • Postpones Enforcement to the Earlier of Six Months from the Date the AGO Adopts its Regulations or July 1, 2020 (Section 1798.185(c)): In a corresponding change to that noted above, SB 1121 also extends the date on which the AGO can begin enforcing the CCPA by the earlier of either six months from the date that the AGO adopts its final CCPA-related regulations or July 1, 2020. Should the AGO adopt its final regulations on July 1, 2020, it appears that businesses may be faced with having to comply with those regulations on the first day that they are promulgated.
  • Makes Statewide Preemption Provision Effective Immediately (Section 1798.199): The revisions speed up enforcement of the statewide preemption provision to ensure that it takes effect immediately upon the Governor signing SB 1121 into law. This revision is a direct response to local privacy protection efforts, including a ballot initiative set to go before San Francisco voters this November. The San Francisco initiative could result in a “Privacy First Policy” to which the city, its contractors and its permit holders would have to adhere. The Policy is made up of 11 principles that effectively give city residents and certain guests greater control over how their personal information is collected, stored and shared. If the initiative is passed, the city government would have to consider the Policy when drafting and proposing a privacy ordinance containing more detailed rules. SB 1121 would undercut this local effort by ensuring that the CCPA’s requirements preempt certain local laws statewide.
  • Removes Various Prerequisites to a Consumer Pursuing a Private Right of Action (Section 1798.150(b)(2), (3)): SB 1121 removes Subsection 1798.150(b)(2) and (3) from the CCPA, which required consumers to notify the AGO within 30 days of filing a private right of action and then outlined the potential responses of the AGO to that notice. Some of the AGO responses under Subsection 1798.150(b)(2) appeared to limit consumers’ ability to pursue their private rights of action if the AGO responded in a certain manner. In his August 22 letter, Attorney Gmaeneral Becerra complained of the onus that these provisions would put on the AGO and requested that they be eliminated. Should this revision be adopted, the only prerequisite a consumer will have prior to pursuing a private right of action is providing a business 30 days’ notice of an alleged violation and a chance to cure.
  • Modifies the GLBA Exemption (Section 1798.145(e)): The revised GLBA exemption eliminates the original requirement that it would apply only if the CCPA was in conflict with the GLBA (it would now apply even if there was no conflict). It also expands its protection to include personal information covered by the California Financial Information Privacy Act (Cal. Fin. Code § 4050 et seq.). However, SB 1121 adds language explicitly excluding Section 1798.150, which grants a consumer a private right of action, from the exemption. Business groups sought to revise this section in an effort to simplify compliance for companies that have already undertaken significant work and expense to ensure compliance with the GLBA. It is not clear if that goal was entirely achieved, given the exclusion of the private right of action provision from the exemption.
  • Modifies Medical Information Exemptions to Expand Coverage (Section 1798.145(c)): While the CCPA included an exemption aimed at limiting its applicability where privacy protection already existed under the California Confidentiality of Medical Information Act (CMIA) (Cal. Civ. Code Part § 56 et seq.) or the Health Insurance Portability and Accountability Act of 1996 and the Health Information Technology for Economic and Clinical Health Act of 2009 (together with their implementing regulations, HIPAA), the provision was poorly crafted and unduly narrow. SB 1121 overhauls this provision, making important improvements. “Medical information” as defined under and governed by CMIA is exempted. “Protected health information” as defined under HIPAA that is collected by a HIPAA-covered entity (such as a hospital or a health plan) or business associate (such as a vendor providing services for the hospital or a health plan that involve processing protected health information) is also exempted. “Providers of health care” as defined under CMIA and HIPAA-covered entities are exempted to the extent that they maintain patient information in the same manner as medical information or protected health information in accordance with CMIA and HIPAA, as applicable. Questions remain as to whether a company offering a mobile health app that collects information directly from individuals, without the involvement of a licensed health care professional, may take advantage of these exemptions. In addition, SB 1121 adds a new exemption for information collected as part of clinical trials, as long as the study was subject to certain human-research, subject-protection requirements.
  • Emphasizes the Broad Definition of Personal Information (Section 1798.140(o)(1)): Revisions to the existing definition of “personal information” in SB 1121 emphasize that the term was intended to apply broadly by adding additional language stating that personal information includes the various examples listed in the CCPA if “it identifies, relates to, describes, is capable of being associated with or could be reasonably linked, directly or indirectly, with a particular consumer or household.” This reemphasis contrasts with requests from business groups to narrow the definition to exclude household information and to limit the definition to information that is actually linkable to a specific individual.
  • Continues Requirement for Intentional Conduct to Trigger Highest Penalty (Section 1798.155(b)): At least one of the various iterations of SB 1121 (as amended on August 24) would have amended the CCPA to permit the AGO to seek the highest civil penalty ($7,500) for any violation of the CCPA, intentional or otherwise. However, the final version of SB 1121 reimposed the original limits in the CCPA, including a $2,500 cap for the amount that the AGO can seek for general violations and a $7,500 cap for the amount that the AGO can seek for intentional violations.

III. Conclusion

The CCPA goes into effect on January 1, 2020. It remains to be seen whether the business community will continue to push for further CCPA amendments when the Legislature returns in December. These efforts may intensify as more businesses nationwide realize the CCPA’s far-reaching scope. Indeed, some estimates suggest that as many as 500,000 companies may fall under the statute. With Democrats expected to increase their large majorities in both houses of the Legislature in November, there may be little appetite to scale back CCPA consumer protections. Gov. Jerry Brown (D), who was instrumental in brokering the compromise to keep the Mctaggart measure off the ballot, is also set to leave office at the end of his current term. In addition, there is a likelihood that the CCPA may further embolden other state and local governments outside of California to adopt similar measures. Getting ahead of some of these privacy issues now, before they go into full force in California, may provide businesses with the best means of driving policy development in an area that is sure to affect business practices and costs for years to come.

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

Related Case Law

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

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

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

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

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

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

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

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

California Privacy Rights

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

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

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

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

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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