U.S. Supreme Court Builds On Individuals’ Privacy Rights

by Alston & Bird
Contact

In a landmark Fourth Amendment case, the U.S. Supreme Court ruled that digital is different. A cross-practice team from our National Security & Digital Crimes and Cybersecurity Preparedness & Response teams parse the narrow ruling that brings searches and seizures into the 21st century.

  • The third-party doctrine spelled out in U.S. v. Jones
  • Digital information is more “encyclopedic” than a pen register
  • The significance and implications of Carpenter v. U.S.

The Supreme Court’s recent decision in Carpenter v. United States continues to generate interest more than a month after its release. While the Court proclaimed its holding as narrow, its unprecedented recognition of an individual’s privacy interest in data held by third parties could signal important changes in privacy more generally.

Background

Timothy Carpenter was convicted for his participation in a series of armed robberies.[1] While investigating Carpenter, law enforcement obtained court orders for cell-site location information under the Stored Communications Act (SCA). The SCA requires a showing of “specific and articulable facts … that there are reasonable grounds to believe that the contents of a wire or electronic communication, or the records or other information sought, are relevant and material to an ongoing criminal investigation.”[2]

The court orders requested cell-site location information for periods of 127 days from one cell phone carrier and seven days from another.[3] The government’s expert witness at Carpenter’s trial explained that cell phone carriers log certain information each time a cell phone accesses the wireless network. Using this information, the government produced “maps that placed Carpenter’s phone near four of the charged robberies.”[4]

Carpenter argued that the government’s seizure of his cell-site location information violated the Fourth Amendment because he had a reasonable expectation of privacy in the cell-site location information and because the government had not obtained a warrant supported by probable cause.[5]

Legal Landscape

The Fourth Amendment protects against “unreasonable searches and seizures” of “persons, houses, papers, and effects.” In Katz v. United States, 389 U.S. 347, 351 (1967), the Supreme Court extended this protection to an individual’s “reasonable expectation of privacy,” beginning a lengthy line of cases testing the boundaries of privacy.

According to the majority opinion, Carpenter sits at the intersection of two sets of Fourth Amendment cases. The first, beginning with United States v. Jones, 565 U.S. 400 (2012), recognized an individual’s expectation of privacy in a long-term surveillance of physical location and movement. Before Jones, the Court had held that augmented visual surveillance, involving use of a beeper attached to a vehicle and resulting in the tracking of an individual’s movements, did not constitute a search.[6] The Supreme Court held in Jones that the placement of a GPS tracking device on a car was a trespass, and thus the collection of 28 days of location data using that device was a Fourth Amendment search.[7] More importantly, a collection of five concurrences in Jones agreed that “longer term GPS monitoring,” in certain circumstances, “impinges on expectations of privacy.”[8] It is this agreement among the concurrences that forms the first pillar of the Court’s holding in Carpenter.

The second set of Fourth Amendment cases relates to what is commonly known as the third-party doctrine. That long-standing doctrine holds that an individual generally “has no legitimate expectation of privacy in information he voluntarily turns over to third parties.”[9] The Court has applied the third-party doctrine in contexts as varied as bank records and pen registers (that is, records of dialed phone numbers). For example, in United States v. Miller, 425 U.S. 435 (1976), the Court rejected a Fourth Amendment challenge to the collection of bank records partly because the records were not confidential and contained information that was exposed to the bank as part of the bank’s business. Similarly, the Court has rejected a challenge to the use of a pen register because the dialed numbers are used by the telephone company.[10]

Court’s Decision

The Supreme Court, by a 5–4 majority, agreed with Carpenter and held that the government’s acquisition of cell-site location information covering a period of seven days or more was a search under the Fourth Amendment. In doing so, the Court for the first time recognized an individual’s reasonable expectation of privacy in information generated and maintained by third parties in the course of business. The Court characterized the cell-site location information as “detailed, encyclopedic, and effortlessly compiled.”[11] The Court emphasized that a comprehensive record of an individual’s movements was sufficiently different from bank records and pen register information to which the Court had previously applied the third-party doctrine.[12]

As the Court made clear, the comprehensive nature of the information at issue was a key consideration in its decision. An “all-encompassing record of the holder’s whereabouts,” capable of revealing information about not only “particular movements” but also “familial, political, professional, religious, and sexual associations,” posed privacy concerns.[13] The ubiquity of cell phone usage and the fact that the data in question was retrospective in nature also factored into the Court’s reasoning.[14] Notably, the Court explicitly based its reasoning on the likelihood that cell-site location information would improve, amplifying the privacy concerns associated with unfettered access to such information.[15]

The Court took pains to emphasize Carpenter’s limited Fourth Amendment application at great length: the decision does not address the real-time capture of cell-site location information (as opposed to retrospective collection), collection of cell-site location information covering a shorter period of time, or the capture of information on all devices that connected to a particular cell site during a particular time period. Nor does Carpenter itself upturn application of the third-party doctrine in other areas,[16] such as for bank records or pen register information, or invalidate legal process standards under the SCA or ECPA. However, as the dissents make clear, Carpenter represents a substantial departure from existing precedent under the third-party doctrine.[17]

Analysis

The Carpenter decision departs substantially from previous Fourth Amendment doctrine, expanding individuals’ privacy interests in automatically and ubiquitously collected digital data held by third parties. Rather than apply the traditional bright-line rule that information given to a third-party loses Fourth Amendment privacy protection, the Court employed a kind of balancing test, focusing on the substance and nature of the information at issue along with the circumstances of its collection in determining whether individuals retained privacy interests in the information. By abandoning the previous bright-line rule, the Court invites substantial follow-on litigation with potentially broad applications.

Privacy interest in a “comprehensive record”

Carpenter signals a shift in the characterization of Fourth Amendment privacy interests. Rather than hinging Fourth Amendment protection on an individual’s “persons, houses, papers, and effects,” or on whether the information is a business record or has been disclosed to a third party, the Court’s decision weighs the sensitive nature of certain data—data that reveals the whole of a person’s physical movements. Regardless of whether a third party generates such information or “the Government employs its own surveillance technology” to generate it, the Court has for the first time held that an individual has a reasonable expectation of privacy in comprehensive records of their movements, even when those records are held by a third party.[18]

Put differently, the Carpenter decision recognized an individual’s expectation of privacy in a comprehensive record of their movement generated and held by a third party, while the Jones concurrences recognized an individual’s expectation of privacy in a comprehensive record of their public movements tracked and compiled by the government through a GPS tracker. By its terms, the Fourth Amendment protects the right of individuals “to be secure in their persons, houses, papers, and effects.” In combination, the Carpenter decision and Jones concurrences imply that a comprehensive record of an individual’s movements constitutes a paper or effect that belongs to the individual even when the record is not within the individual’s possession and is not generated by the individual.

Privacy and the compilation of data

Carpenter continues the Court’s recent interest in the compilation of data and digital technologies, underscoring the rationale for establishing arguably separate standards for digital and non-digital data. In particular, Carpenter discusses the “detailed, encyclopedic, and effortlessly compiled” nature of the location information at issue, its “ability to chronicle a person’s past movements,” and the continued and ongoing improvements in the underlying technology.[19] This discussion echoes the concurring opinions in Jones, which point to the wealth of information afforded by GPS monitoring and raise interesting questions about the broad array of data held by third parties and routinely compiled: phone numbers dialed or texted, URLs visited, emails exchanged, and even goods purchased.[20] Along those lines, Riley v. California carved out an exception for digital data, protecting cellular telephones from being searched incident to arrest. According to the Court in Riley, the collection of “many distinct types of information” on cell phones raised unique privacy concerns.[21]

Taken together, the Court’s recent jurisprudence shows an underlying concern with the unprecedented availability of large amounts of comprehensive data through digital technologies. The Court’s opinion in Carpenter abandons the traditional Fourth Amendment dividing line between private information and information held by third parties at least when huge volumes of digital data are generated, compiled, and stored automatically. Likewise, five Justices in Jones recognized a privacy interest even when location information is exposed to the public if it covers a sufficient length of time. And in Riley, the Court held that the nature and quantity of data on cell phones today is too great to fall under the rubric of a traditional warrantless arrest search. Digital, the Court is telling us, is different.

Takeaways

The Court’s reasoning carries significance for privacy in the digital age. As a starting point, Carpenter portends only the beginning, rather than the end, of litigation concerning the third-party doctrine as it relates to digital data. While Carpenter focuses on a person’s expectation of privacy in a comprehensive record of the person’s movements, it is easy to imagine other scenarios in which the compilation of data exposed to the public or maintained by third parties produces similarly sensitive records. And as Justice Sotomayor’s concurrence in the Jones case points out, we should not assume that an individual lacks an expectation of privacy in, for example, a comprehensive web browsing history or other online activities. More generally, Carpenter comes at a time of potential upheaval in the privacy space. Carpenter’s ramifications will be litigated heavily at the state and federal levels, and its fallout may greatly interest legislators and privacy advocates in this country and elsewhere.


[1] Carpenter, 585 U. S. ____ (2018) (slip op., at 4).
[2] 18 U.S.C. § 2703(d).
[3] Carpenter, 585 U. S. ____ (slip op., at 3). Note that the request for seven days of cell-site location information yielded only two days’ worth of data.
[4] Id. at 3-4.
[5] Id. at 3.
[6] United States v. Knotts, 460 U. S. 276 (1983).
[7] United States v. Jones, 565 U.S. 400, 404 (2012)
[8] Id. at 430 (ALITO, J., concurring in judgement); id., at 415 (SOTOMAYOR, J., concurring).
[9] Smith v. Maryland, 442 U.S. 735, 743-744 (1979).
[10] Id. at 742.
[11] Carpenter, 585 U. S. ____ (slip op., at 10).
[12] Id. at 11.
[13] Id. at 12.
[14] Id. at 12-13.
[15] Id. at 14.
[16] Id. at 17-18.
[17] Carpenter, 585 U. S. ____ (slip op., at 7) (KENNEDY, J., dissenting).
[18] Carpenter, 585 U. S. ____ (slip op., at 11).
[19] Carpenter, 585 U. S. ____ (slip op., at 10).
[20] See Jones, 565 U.S. 400, 428 (SOTOMAYOR, J., concurring).
[21] Riley v. California, 573 U.S. __ , __ (2014) (slip op., at 18).

Download PDF of Advisory

[View source.]

 

 

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.

© Alston & Bird | Attorney Advertising

Written by:

Alston & Bird
Contact
more
less

Alston & Bird 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.