What a “No Deal” Brexit Means for UK Data Privacy

Latham & Watkins LLP

Understanding the practical implications of a “No Deal” Brexit (as compared to an exit under an approved Withdrawal Agreement) following last week’s vote against the current withdrawal proposal.

“No Deal” Brexit

Unless the UK can agree on a deal with the EU that meets the approval of the majority of the UK Parliament, withdraws its Article 50 notice, or can negotiate with the EU an extension to the 29 March 2019 departure (Exit Date), the UK will leave the EU without a ratified Withdrawal Agreement or an agreed Political Declaration (together, the Deal). The political uncertainties around the different scenarios warrant that businesses prepare for a “No Deal” Brexit in all areas, including in relation to the processing of personal data.

Under a “No Deal” Brexit scenario, the General Data Protection Regulation (GDPR) will form part of UK domestic law as “retained EU law” as a result of the EU (Withdrawal) Act 2018 (EUWA), with certain amendments made to it and also to the Data Protection Act 2018 and the UK Privacy and Electronic Communications (EC Directive) Regulations 2003 under the (draft) Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (Privacy Exit Regulations), which is intended to come into force on the Exit Date. This is collectively being referred to as the “UK GDPR”.

The Privacy Exit Regulations are necessary to replace references to EU law, institutions and procedures with UK domestic equivalents so that the regime established by the UK GDPR can function properly in a post-Brexit context. The proposed amendments ensure that the UK GDPR will have extraterritorial effect in the same way as the GDPR. The UK GDPR will apply to controllers and processors located outside the UK whose processing activities relate to offering goods or services to individuals in the UK or to the monitoring of the behaviour of individuals in the UK.

Here are the five key areas in which businesses will need to take action to prepare for a “No Deal” Brexit:

1. Data Transfers From the European Economic Area (EEA) to the UK. The UK will become a “third country” on the Exit Date. The European Commission will not be able to issue an adequacy decision regarding the UK by the Exit Date (at least, not unless the Exit Date is materially delayed). Businesses transferring data from the EEA into the UK will need to put in place a data transfer solution. Since there is no equivalent of the US Privacy Shield, the European Commission-approved standard contractual clauses (SCCs) (i.e., model clauses) will be the main option for businesses, unless they have Binding Corporate Rules (BCRs) already authorised or can rely on an Article 49 derogation.

With regard to such data transfers, businesses should update their privacy notices and record of processing to reflect any changes to their data transfer solutions. Current BCRs will need to be updated to make clear the UK is a third country. For BCRs that are authorised by the UK Information Commissioner’s Office (ICO), businesses will need to find a lead supervisory authority for the purpose of such BCRs within the EU/EEA.

Data Transfers From the UK to Other Countries: Such data transfers will remain largely unaffected. Here is what companies need to know regarding transfers from the UK…

… to the EEA: The UK government will “transitionally recognise” all EEA countries as providing an adequate level of protection. The UK government says it will keep this transitional arrangement under review.

… to “adequate” countries: The UK government will recognise the EU adequacy decisions that have been made by the European Commission prior to the Exit Date. As a result, transfers from the UK to countries covered by an EU adequacy decision can continue uninterrupted.

… under SCCs: The UK government will recognise SCCs as continuing to provide an appropriate safeguard for transfers from the UK to “third countries” (meaning non-EEA countries and those not subject to an adequacy decision). As such, UK organisations can continue to rely on SCCs that have been entered into prior to the Exit Date and UK organisations may continue to enter into SCCs after the Exit Date.

… under BCRs: The UK government will recognise BCRs authorised before the Exit Date as ensuring appropriate safeguards for transfers from the UK. Accordingly, current BCRs that are in place covering a UK export of data can continue to be relied on. However, the ICO advises that organisations update their BCRs, so that the UK is listed as a third country outside the EEA (but covered by export in regard to BCRs that have already been authorised). In regard to BCRs that are authorised by the ICO after the Exit Date, the ICO will authorise these under domestic law.

… under the Privacy Shield to the US: UK businesses can continue to transfer personal data to US organisations participating in the Privacy Shield, provided that those US organisations have updated their public commitment to comply with the Privacy Shield to expressly state that those commitments apply to transfers of personal data from the UK. Further information on this can be found on the US government’s Privacy Shield website.

2. UK and EU/EEA Representatives. The UK government will require controllers or processors located outside of the UK but which are offering goods or services to, or monitoring, individuals located in the UK to appoint a UK representative. The ICO notes that, as a result, some organisations may require both a UK representative under the UK GDPR and an EU/EEA representative under the GDPR (if the organisation is offering goods or services to, or monitoring, individuals located in a the UK and an EU/EEA Member State).

3. Data Protection Officers (DPOs). If an organisation is required to have a DPO under the GDPR, the same requirement will continue to apply under the UK GDPR. According to the ICO, companies “may continue to have a DPO who covers the UK and EEA. The UK and EU GDPRs will both require that your DPO is ‘easily accessible from each establishment’ in the EEA and UK”. However, this does not exclude the possibility of appointing the same DPO for the UK and EEA countries.

4. The ICO’s Role Post-Brexit (Can It Still Be a Lead Authority?). From the Exit Date, the ICO can no longer act as a lead authority for the purposes of the GDPR. However, the ICO says it “will still cooperate and collaborate with European supervisory authorities, as we did before GDPR and the one-stop-shop system, regarding any breaches of GDPR that affect individuals in the UK and other EU and EEA states”. The ICO advises: “If you will continue to carry out cross-border processing, and your current lead authority is the ICO, review the EDPB guidelines for identifying a controller or processor’s lead supervisory authority (last revised in April 2017), and consider which other EU and EEA supervisory authority will become lead authority on Exit Date (if any). You may want to contact them closer to exit date”. The ICO will, of course, continue to be what it calls the “independent supervisory body” for enforcement of the UK’s data protection regime.

5. The European Data Protection Board. The ICO will no longer be a member of the EDPB, which is the body established by the GDPR and made up of EU/EEA supervisory authorities in order to ensure consistency within the EU/EEA regarding interpretation of the GDPR and approach to regulatory action. However, the ICO has said it will seek to retain a strong relationship with the EDPB. Giovanni Buttarelli, the European Data Protection Supervisor, has said that he aims to “arrange the architecture to find a solution” to keep the ICO actively engaged with the EDPB.

When the authors of this blog post asked the ICO on 15 January 2019 about investigations that are currently in progress for which the ICO is acting as a lead authority, the ICO said it hopes to finalise any pending investigations, but that it will need to publish further guidance on this point. The ICO states on its website that it will be updating its “Guide to GDPR” to cover cross-border processing, lead supervisory authorities, and the one-stop shop in due course. In the meantime, it gives four scenarios to help organisations navigate the one-stop shop after Brexit, defining “cross-border processing” as when an organisation has an office, branch, or other establishment in the UK and its processing is likely to affect individuals in one or more EU or EEA states:

  • Scenario 1: Where an organisation is currently cross-border processing in relation to two establishments (UK and EU/EEA) and the processing is not likely to substantially affect individuals in any additional EU or EEA state, then from the Exit Date it will have to deal with both the ICO and the supervisory authority in its EU/EEA establishment.
  • Scenario 2: Where an organisation is currently cross-border processing in relation to two establishments (UK and EU/EEA) and the processing in the context of the activities of both the UK and EU/EEA establishment is likely to substantially affect individuals in other EU or EEA states, then from the Exit Date it will have to deal with both the ICO and its EU/EEA lead supervisory authority.
  • Scenario 3: Where an organisation is currently cross-border processing in relation to three or more establishments (UK and two or more in EU/EEA) and the processing may or may not substantially affect individuals in any other EU or EEA state, then from the Exit Date it will have to deal with both the ICO and its EU/EEA lead supervisory authority.
  • Scenario 4: Where an organisation is currently cross-border processing with an establishment in the UK and no establishment in the EU or EEA and its processing is likely to substantially affect individuals in one or more EU or EEA states, then from the Exit Date it will have to deal with the ICO and with the supervisory authorities in all EU and EEA states where individuals are located whose personal data is processed in connection with those activities.

“Deal” Brexit

This is a scenario where the government is able to achieve new terms from the EU and gain approval from the UK Parliament, in which circumstances the UK will leave the EU on the Exit Date under the terms of a revised Withdrawal Agreement and Political Declaration. The UK will then enter into a transition period that is currently due to end on 31 December 2020 but could be extended (Transition Period). It is currently assumed that any renegotiation of the Withdrawal Agreement will not change the provisions on data protection.

Under this scenario, the Privacy Exit Regulations will come into force on the Exit Date, but since there is a Deal, the GDPR will continue to apply during the Transition Period. The GDPR will apply to the UK in the same manner as to any EU/EEA state, other than in regard to the cooperation and consistency under Chapter VII of the GDPR, which appears to be dis-applied by the Privacy Exit Regulations and the Withdrawal Agreement. The role of the ICO in the Transition Period remains unclear and the ICO expects the EDPB to issue further guidance.

The current drafts of the Political Declaration and Withdrawal Agreement provide that an “adequacy” assessment for the UK will start after the Exit Date and that the EU will “endeavour” to adopt an adequacy decision in relation to the UK by the end of the Transition Period. In the meantime, transfers from the EU/EEA to the UK and vice versa will be considered adequate as under the current regime until the expiry of the Transition Period.

What Should Businesses Do Now?

While it is clear to those following Brexit that we continue to live in a period of uncertainty, businesses:

  • That have the UK as a lead authority should reconsider their options and watch for guidance from the EDPB going forward (in particular as to the ICO’s role in the Transition Period for a “deal” Brexit)
  • Should identify EEA to UK data flows and consider putting model clauses in place
  • Whose US entities are certified under the US Privacy Shield must update their certifications and policies to ensure the UK is covered
  • With BCRs should update their policies and documents to recognise the UK as a “third country” outside the EEA (but covered by export in regard to BCRs that have already been authorised) and consider a potential EU/EEA lead authority (see above) if the present lead authority is the UK
  • With no UK presence should consider who will act as their UK representative (who must be located in the UK) if they are subject to UK law because they offer goods or services to data subjects in the UK or monitor their behaviour

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.

© Latham & Watkins LLP | Attorney Advertising

Written by:

Latham & Watkins LLP

Latham & Watkins LLP on:

Readers' Choice 2017
Reporters on Deadline

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

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

JD Supra Privacy Policy

Updated: May 25, 2018:

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

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

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

Collection of Information

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

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

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

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

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

How do we use this information?

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

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

How is your information shared?

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

How We Protect Your Information

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

Children's Information

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

Links to Other Websites

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

Information for EU and Swiss Residents

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

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

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

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

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

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

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

California Privacy Rights

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

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

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

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

Access/Correct/Update/Delete Personal Information

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

Changes in Our Privacy Policy

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

Contacting JD Supra

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

JD Supra Cookie Guide

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

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

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

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

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

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

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

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

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

Controlling and Deleting Cookies

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

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

Updates to This Policy

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

Contacting JD Supra

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

- hide

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