Group items tagged

When the Senate Intelligence Committee passed the Cybersecurity Information Sharing Act by a vote of 14 to 1, committee chairman Senator Richard Burr argued that it successfully balanced security and privacy. Fifteen new amendments to the bill, he said, were designed to protect internet users’ personal information while enabling new ways for companies and federal agencies to coordinate responses to cyberattacks. But critics within the security and privacy communities still have two fundamental problems with the legislation: First, they say, the proposed cybersecurity act won’t actually boost security. And second, the “information sharing” it describes sounds more than ever like a backchannel for surveillance.

On Tuesday the bill’s authors released the full, updated text of the CISA legislation passed last week, and critics say the changes have done little to assuage their fears about wanton sharing of Americans’ private data. In fact, legal analysts say the changes actually widen the backdoor leading from private firms to intelligence agencies. “It’s a complete failure to strengthen the privacy protections of the bill,” says Robyn Greene, a policy lawyer for the Open Technology Institute, which joined a coalition of dozens of non-profits and cybersecurity experts criticizing the bill in an open letter earlier this month. “None of the [privacy-related] points we raised in our coalition letter to the committee was effectively addressed.” The central concern of that letter was how the same data sharing meant to bolster cybersecurity for companies and the government opens massive surveillance loopholes. The bill, as worded, lets a private company share with the Department of Homeland Security any information construed as a cybersecurity threat “notwithstanding any other provision of law.” That means CISA trumps privacy laws like the Electronic Communication Privacy Act of 1986 and the Privacy Act of 1974, which restrict eavesdropping and sharing of users’ communications. And once the DHS obtains the information, it would automatically be shared with the NSA, the Department of Defense (including Cyber Command), and the Office of the Director of National Intelligence.

In a statement posted to his website yesterday, Senator Burr wrote that “Information sharing is purely voluntary and companies can only share cyber-threat information and the government may only use shared data for cybersecurity purposes.” But in fact, the bill’s data sharing isn’t limited to cybersecurity “threat indicators”—warnings of incoming hacker attacks, which is the central data CISA is meant to disseminate among companies and three-letter agencies. OTI’s Greene says it also gives companies a mandate to share with the government any data related to imminent terrorist attacks, weapons of mass destruction, or even other information related to violent crimes like robbery and carjacking. 

The nation’s top technology firms and a coalition of privacy groups are urging Congress to place curbs on government surveillance in the face of a fast-approaching deadline for legislative action. A set of key Patriot Act surveillance authorities expire June 1, but the effective date is May 21 — the last day before Congress breaks for a Memorial Day recess. In a letter to be sent Wednesday to the Obama administration and senior lawmakers, the coalition vowed to oppose any legislation that, among other things, does not ban the “bulk collection” of Americans’ phone records and other data.

We know that there are some in Congress who think that they can get away with reauthorizing the expiring provisions of the Patriot Act without any reforms at all,” said Kevin Bankston, policy director of New America Foundation’s Open Technology Institute, a privacy group that organized the effort. “This letter draws a line in the sand that makes clear that the privacy community and the Internet industry do not intend to let that happen without a fight.” At issue is the bulk collection of Americans’ data by intelligence agencies such as the National Security Agency. The NSA’s daily gathering of millions of records logging phone call times, lengths and other “metadata” stirred controversy when it was revealed in June 2013 by former NSA contractor Edward Snowden. The records are placed in a database that can, with a judge’s permission, be searched for links to foreign terrorists.They do not include the content of conversations.

That program, placed under federal surveillance court oversight in 2006, was authorized by the court in secret under Section 215 of the Patriot Act — one of the expiring provisions. The public outcry that ensued after the program was disclosed forced President Obama in January 2014 to call for an end to the NSA’s storage of the data. He also appealed to Congress to find a way to preserve the agency’s access to the data for counterterrorism information.

Pending before federal magistrate judge James Orenstein is the government’s request for an order obligating Apple, Inc. to unlock an iPhone and thereby assist prosecutors in decrypting data the government has seized and is authorized to search pursuant to a warrant. In an order questioning the government’s purported legal basis for this request, the All Writs Act of 1789 (AWA), Judge Orenstein asked Apple for a brief informing the court whether the request would be technically feasible and/or burdensome. After Apple filed, the court asked it to file a brief discussing whether the government had legal grounds under the AWA to compel Apple’s assistance. Apple filed that brief and the government filed a reply brief last week in the lead-up to a hearing this morning.

We’ve long been concerned about whether end users own software under the law. Software owners have rights of adaptation and first sale enshrined in copyright law. But software publishers have claimed that end users are merely licensees, and our rights under copyright law can be waived by mass-market end user license agreements, or EULAs. Over the years, Granick has argued that users should retain their rights even if mass-market licenses purport to take them away. The government’s brief takes advantage of Apple’s EULA for iOS to argue that Apple, the software publisher, is responsible for iPhones around the world. Apple’s EULA states that when you buy an iPhone, you’re not buying the iOS software it runs, you’re just licensing it from Apple. The government argues that having designed a passcode feature into a copy of software which it owns and licenses rather than sells, Apple can be compelled under the All Writs Act to bypass the passcode on a defendant’s iPhone pursuant to a search warrant and thereby access the software owned by Apple. Apple’s supplemental brief argues that in defining its users’ contractual rights vis-à-vis Apple with regard to Apple’s intellectual property, Apple in no way waived its own due process rights vis-à-vis the government with regard to users’ devices. Apple’s brief compares this argument to forcing a car manufacturer to “provide law enforcement with access to the vehicle or to alter its functionality at the government’s request” merely because the car contains licensed software. 

This is an interesting twist on the decades-long EULA versus users’ rights fight. As far as we know, this is the first time that the government has piggybacked on EULAs to try to compel software companies to provide assistance to law enforcement. Under the government’s interpretation of the All Writs Act, anyone who makes software could be dragooned into assisting the government in investigating users of the software. If the court adopts this view, it would give investigators immense power. The quotidian aspects of our lives increasingly involve software (from our cars to our TVs to our health to our home appliances), and most of that software is arguably licensed, not bought. Conscripting software makers to collect information on us would afford the government access to the most intimate information about us, on the strength of some words in some license agreements that people never read. (And no wonder: The iPhone’s EULA came to over 300 pages when the government filed it as an exhibit to its brief.)

EFF, Human Rights Watch, and Over 70 Civil Society Groups Ask Mark Zuckerberg to Provide All Users with Mechanism to Appeal Content Censorship on Facebook World’s Freedom of Expression Is In Your Hands, Groups Tell CEO San Francisco—The Electronic Frontier Foundation (EFF) and more than 70 human and digital rights groups called on Mark Zuckerberg today to add real transparency and accountability to Facebook’s content removal process. Specifically, the groups demand that Facebook clearly explain how much content it removes, both rightly and wrongly, and provide all users with a fair and timely method to appeal removals and get their content back up. While Facebook is under enormous—and still mounting—pressure to remove material that is truly threatening, without transparency, fairness, and processes to identify and correct mistakes, Facebook’s content takedown policies too often backfire and silence the very people that should have their voices heard on the platform.  Politicians, museums, celebrities, and other high profile groups and individuals whose improperly removed content can garner media attention seem to have little trouble reaching Facebook to have content restored—they sometimes even receive an apology. But the average user? Not so much. Facebook only allows people to appeal content decisions in a limited set of circumstances, and in many cases, users have absolutely no option to appeal. Onlinecensorship.org, an EFF project for users to report takedown notices, has collected reports of hundreds of unjustified takedown incidents where appeals were unavailable. For most users, content Facebook removes is rarely restored, and some are banned from the platform for no good reason. EFF, Article 19, the Center for Democracy and Technology, and Ranking Digital Rights wrote directly to Mark Zuckerberg today demanding that Facebook implement common sense standards so that average users can easily appeal content moderation decisions, receive prompt replies and timely review by a human or humans, and have the opportunity to present evidence during the review process. The letter was co-signed by more than 70 human rights, digital rights, and civil liberties organizations from South America, Europe, the Middle East, Asia, Africa, and the U.S.

California has passed a digital privacy law granting consumers more control over and insight into the spread of their personal information online, creating one of the most significant regulations overseeing the data-collection practices of technology companies in the United States.The bill raced through the State Legislature without opposition on Thursday and was signed into law by Gov. Jerry Brown, just hours before a deadline to pull from the November ballot an initiative seeking even tougher oversight over technology companies.The new law grants consumers the right to know what information companies are collecting about them, why they are collecting that data and with whom they are sharing it. It gives consumers the right to tell companies to delete their information as well as to not sell or share their data. Businesses must still give consumers who opt out the same quality of service.It also makes it more difficult to share or sell data on children younger than 16.The legislation, which goes into effect in January 2020, makes it easier for consumers to sue companies after a data breach. And it gives the state’s attorney general more authority to fine companies that don’t adhere to the new regulations.

The California law is not as expansive as Europe’s General Data Protection Regulation, or G.D.P.R., a new set of laws restricting how tech companies collect, store and use personal data.But Aleecia M. McDonald, an incoming assistant professor at Carnegie Mellon University who specializes in privacy policy, said California’s privacy measure was one of the most comprehensive in the United States, since most existing laws — and there are not many — do little to limit what companies can do with consumer information.

Federal regulators are discussing whether and how to hold Facebook Chief Executive Mark Zuckerberg personally accountable for the company's history of mismanaging users' private data, two sources familiar with the discussions told NBC News on Thursday.The sources wouldn't elaborate on what measures are specifically under consideration. The Washington Post, which first reported the development, reported that regulators were exploring increased oversight of Zuckerberg's leadership.While Facebook has come under scrutiny for its privacy practices for years, both of the Democratic members of the FTC have said the agency should target individual executives when appropriate.Justin Brookman, a former policy director for technology research at the Federal Trade Commission, or FTC, said Thursday night that while the FTC can name individual company leaders if they directed, controlled and knew about any wrongdoing, "they typically only use that authority in fraud-like cases, so far as I can tell."

Facebook's thousands of employees are reportedly unable to use the company's internal iOS apps after it was caught running a data-gathering research app that violated Apple's developer policies. Apple said on Wednesday that it had revoked Facebook's certificates giving it access to a special enterprise program that companies can use to distribute internal apps and tools outside the public App Store. The move has caused internal Facebook apps to stop working, creating a chaotic situation that the company has deemed a critical problem, The Verge reported. Facebook employees reportedly can't open company apps for transportation and the lunch menu, along with beta versions of Facebook apps like Messenger and Instagram.

Lawmakers in the United States and the United Kingdom are calling on Facebook chief executive Mark Zuckerberg to explain how the names, preferences and other information from tens of millions of users ended up in the hands of the Cambridge Analytica data analysis firm.

After Facebook cited data privacy policies violations and announced that it was suspending the Cambridge Analytica data analytics firm also tied to the Trump campaign, new revelations have emerged. On Saturday, reports revealed that Cambridge Analytica, used a feature once available to Facebook app developers to collect information on some 270,000 people. In the process, the company, which was, at the time, handling U.S. President Donald Trump’s presidential campaign, gained access to data on tens of millions of their Facebook “friends” and that it wasn’t clear at all if any of these people had given explicit permission for this kind of sharing. Facebook’s Deputy General Counsel Paul Grewal said in a statement, “We will take legal action if necessary to hold them responsible and accountable for any unlawful behavior.”

The social media giant also added that it was continuing to investigate the claims. According to reports, Cambridge Analytica worked for the failed presidential campaign of U.S. Senator Ted Cruz and then for the presidential campaign of Donald Trump. Federal Election Commission records reportedly show that Trump’s campaign hired Cambridge Analytica in June 2016 and paid it more than $6.2 million. On its website, the company says that it “provided the Donald J. Trump for President campaign with the expertise and insights that helped win the White House.” Cambridge Analytica also mentions that it uses “behavioral microtargeting,” or combining analysis of people’s personalities with demographics, to predict and influence mass behavior.  According to the company, it has data on 220 million Americans, two thirds of the U.S. population. Cambridge Analytica says it has worked on other campaigns in the United States and other countries, and it is funded by Robert Mercer, a prominent supporter of politically conservative groups.

Imagine if someone could scan every image on Facebook, Twitter, and Instagram, then instantly determine where each was taken. The ability to combine this location data with information about who appears in those photos—and any social media contacts tied to them—would make it possible for government agencies to quickly track terrorist groups posting propaganda photos. (And, really, just about anyone else.) That's precisely the goal of Finder, a research program of the Intelligence Advanced Research Projects Agency (IARPA), the Office of the Director of National Intelligence's dedicated research organization. For many photos taken with smartphones (and with some consumer cameras), geolocation information is saved with the image by default. The location is stored in the Exif (Exchangable Image File Format) data of the photo itself unless geolocation services are turned off. If you have used Apple's iCloud photo store or Google Photos, you've probably created a rich map of your pattern of life through geotagged metadata. However, this location data is pruned off for privacy reasons when images are uploaded to some social media services, and privacy-conscious photographers (particularly those concerned about potential drone strikes) will purposely disable geotagging on their devices and social media accounts.

An analysis of public comments on the FCC's plan to repeal net neutrality rules found that 2 million of them were filed using stolen identities. That's according to New York Attorney General Eric Schneiderman. "Millions of fake comments have corrupted the FCC public process—including two million that stole the identities of real people, a crime under New York law," Schneiderman said in an announcement today. "Yet the FCC is moving full steam ahead with a vote based on this corrupted process, while refusing to cooperate with an investigation."

Some comments were submitted under the names of dead people. "My LATE husband's name was fraudulently used after a valiant battle with cancer," one person told the AG's office. "This unlawful act adds to my pain that someone would violate his good name." Schneiderman set up a website where people can search the FCC comments for their names to determine if they've been impersonated. So far, "over 5,000 people have filed reports with the Attorney General's office regarding identities used to submit fake comments," the AG's announcement said.

While the 5,000 reports provide anecdotal evidence, the AG's office performed an analysis of the 23 million public comments in order to figure out how many were submitted under falsely assumed identities. Many comments for and against net neutrality rules are identical because advocacy groups urged people to sign form letters, so the text of a comment alone isn't enough to determine if it was submitted by a real person. The AG's office thus examined comment text along with other factors, such as whether names matched lists of stolen identities from known data breaches. Schneiderman's office also told Ars that it looked into whether or not the submission of comments was in alphabetical order, one after another, in short time periods. In general, analysis of formatting and metadata played a role in the analysis. The number of comments believed to be fake has grown as the A.G.'s investigation continues, and it isn't done yet. Schneiderman's office is still analyzing the public comments. We asked Schneiderman's office how many of the fake comments supported net neutrality rules, and how many opposed them, but were told that the information was not available. While fake comments used names and addresses of people from across the nation, more than "100,000 comments per state" came "from New York, Florida, Texas, and California," Schneiderman's announcement said.

he National Security Agency (NSA) collected over 530 million phone records of Americans in 2017—that's three times the amount the spy agency sucked up in 2016. The figures were released Friday in an annual report from the Office of the Director of National Intelligence (ODNI). It shows that the number of "call detail records" the agency collected from telecommunications providers during Trump's first year in office was 534 million, compared to 151 million the year prior. "The intelligence community's transparency has yet to extend to explaining dramatic increases in their collection," said Robyn Greene, policy counsel at the Open Technology Institute. The content of the calls itself is not collected but so-called "metadata," which, as Gizmodo notes, "is supposedly anonymous, but it can easily be used to identify an individual. The information can also be paired with other publicly available information from social media and other sources to paint a surprisingly detailed picture of a person's life." The report also revealed that the agency, using its controversial Section 702 authority, increased the number of foreign targets of warrantless surveillance. It was 129,080 in 2017 compared to 106,469 in 2016. As digital rights group EFF noted earlier this year, Under Section 702, the NSA collects billions of communications, including those belonging to innocent Americans who are not actually targeted. These communications are then placed in databases that other intelligence and law enforcement agencies can access—for purposes unrelated to national security—without a warrant or any judicial review. "Overall," Jake Laperruque, senior counsel at the Project On Government Oversight, said to ZDNet, "the numbers show that the scale of warrantless surveillance is growing at a significant rate, but ODNI still won't tell Americans how much it affects them."

Several prominent figures, including Web inventor Tim Berners-Lee, warned the EU Parliament that its proposed censorship measure would begin transforming the Internet from an open platform for sharing and innovation, into a tool for the automated surveillance and control of its users.

For much of the year, independent media has felt the sting of increased social media censorship, as the “revolving door” between U.S. intelligence agencies and social-media companies has manifested in a crackdown on news that challenges official government narratives. With many notable independent news websites having shut down since then as a result, those that remain afloat are being censored like never before, with social media traffic from Facebook and Twitter completely cut off in some cases. Among such websites, social media censorship by the most popular social networks is now widely regarded to be the worst it has ever been – a chilling reality for any who seek fact-based perspectives on major world events that differ from those to be found on well-known corporate-media outlets that consistently toe the government line. Last August, MintPress reported that a new Google algorithm targeting “fake news” had quashed traffic to many independent news and advocacy sites, with sites such as the American Civil Liberties Union, Democracy Now, and WikiLeaks, seeing their returns from Google searches experience massive drops. The World Socialist Website, one of the affected pages, reported a 67 percent decrease in Google returns while MintPress experienced an even larger decrease of 76 percent in Google search returns. The new algorithm targeted online publications on both sides of the political spectrum critical of U.S. imperialism, foreign wars, and other long-standing government policies. Now, less than a year later, the situation has become even more dire. Several independent media pages have reported that their social media traffic has sharply declined since March and – in some cases – stopped almost entirely since June began. For instance, independent media website Antimedia – a page with over 2 million likes and follows – saw its traffic drop from around 150,000 page views per day earlier this month to around 12,000 as of this week. As a reference, this time last year Antimedia’s traffic stood at nearly 300,000 a day.

n a blog post on Tuesday, YouTube said it had removed more than 100,000 videos and over 17,000 channels for violating its hate speech rules in April through June, which is five times more than it removed in the previous three months. It also took down over 500 million comments over hate speech. YouTube attributed the increase to its recent efforts to counter the proliferation of hate content. In June, the company updated its hate speech policy to include a ban on supremacist content and the removal of videos that deny well-documented atrocities, such as the Holocaust, and the 2012 shooting rampage at Sandy Hook elementary school.

Since taking office, President Donald Trump has wasted no time in proposing rollbacks to Obama-era federal regulations. So, it should come as no surprise that the Federal Communications Commission (FCC) voted last month to propose changes to current regulations on Internet service providers. Spearheaded by Ajit Pai — the Trump-appointed FCC chairman and former lawyer for Verizon — the 2-1 vote is the first step in dismantling the Open Internet Order. The lone FCC Democrat, Mignon Clyburn, was overruled by Pai and fellow commissioner Michael O’Reilly. The 2015 order classified broadband internet as a utility under Title II of the Communications Act of 1934. Opponents of the current state of net neutrality argue that the rules are archaic and place unnecessary — even harmful — restrictions on internet service providers (ISPs), leading to lack of innovation and investment. While it’s true that policies conceived in the 1930s could hardly anticipate the complexities of the modern Internet, a complete rollback of Title II protections would leave ISPs free to favor their own services and whichever company pays for upgraded service. Considering relaxed FEC rules on media ownership and lack of antitrust enforcement, some could argue that a rollback of net neutrality is even more toxic to innovation and affordable pricing. That is, fast lanes could be created for companies with deeper pockets, effectively giving them an advantage over companies and individuals who can’t pay extra. This approach effectively penalizes small businesses, nonprofits and innovative start-ups. Today’s Internet is so vast and so pervasive that it’s hard to grasp the impact that an abandonment of net neutrality would have on every aspect of our culture.

While the FCC’s proposed change will touch most Americans, net neutrality remains a mystifying concept to non-techies. To help our readers better understand the issue, we have compiled some videos that explain net neutrality and its importance. The FCC will be accepting comments from the public on their website until August 16, 2017.

WikiLeaks has published what it says is another batch of secret hacking manuals belonging to the US Central Intelligence Agency as part of its Vault7 series of leaks. The site is billing Vault7 as the largest publication of intelligence documents ever. Friday's installment includes 27 documents related to "Grasshopper," the codename for a set of software tools used to build customized malware for Windows-based computers. The Grasshopper framework provides building blocks that can be combined in unique ways to suit the requirements of a given surveillance or intelligence operation. The documents are likely to be of interest to potential CIA targets looking for signatures and other signs indicating their Windows systems were hacked. The leak will also prove useful to competing malware developers who want to learn new techniques and best practices. "Grasshopper is a software tool used to build custom installers for target computers running Microsoft Windows operating system," one user guide explained. "An operator uses the Grasshopper builder to construct a custom installation executable."

The White House on Wednesday made public for the first time the rules by which the government decides to disclose or keep secret software flaws that can be turned into cyberweapons — whether by U.S. agencies hacking for foreign intelligence, money-hungry criminals or foreign spies seeking to penetrate American computers. The move to publish an un­classified charter responds to years of criticism that the process was unnecessarily opaque, fueling suspicion that it cloaked a stockpile of software flaws that the National Security Agency was hoarding to go after foreign targets but that put Americans’ cyber­security at risk.

The rules are part of the “Vulnerabilities Equities Process,” which the Obama administration revamped in 2014 as a multi­agency forum to debate whether and when to inform companies such as Microsoft and Juniper that the government has discovered or bought a software flaw that, if weaponized, could affect the security of their product. The Trump administration has mostly not altered the rules under which the government reaches a decision but is disclosing its process. Under the VEP, an “equities review board” of at least a dozen national security and civilian agencies will meet monthly — or more often, if a need arises — to discuss newly discovered vulnerabilities. Besides the NSA, the CIA and the FBI, the list includes the Treasury, Commerce and State departments, and the Office of Management and Budget. The priority is on disclosure, the policy states, to protect core Internet systems, the U.S. economy and critical infrastructure, unless there is “a demonstrable, overriding interest” in using the flaw for intelligence or law enforcement purposes. The government has long said that it discloses the vast majority — more than 90 percent — of the vulnerabilities it discovers or buys in products from defense contractors or other sellers. In recent years, that has amounted to more than 100 a year, according to people familiar with the process. But because the process was classified, the National Security Council, which runs the discussion, was never able to reveal any numbers. Now, Joyce said, the number of flaws disclosed and the number retained will be made public in an annual report. A classified version will be sent to Congress, he said.

Now Google, at the behest of its friends in Washington, is actively censoring – essentially blocking access to – any websites which seek to warn American workers of the ongoing effort to further attack their incomes, social services, and life conditions by the U.S. central government, and which seek to warn against the impending warfare between U.S.-led Nato and other forces against countries like Iran, Russia, and China, which have in no way threatened the U.S. state or its people

Under its new so-called anti-fake-news program, Google algorithms have in the past few months moved socialist, anti-war, and progressive websites from previously prominent positions in Google searches to positions up to 50 search result pages from the first page, essentially removing them from the search results any searcher will see.    CounterPunch, World Socialist Website, Democracy Now, American Civil liberties Union, Wikileaks are just a few of the websites which have experienced severe reductions in their returns from Google searches.  World Socialist Website, to cite just one example, has experienced a 67% drop in its returns from Google since the new policy was announced. This conversion of Google into a Censorship engine is not a trivial development.   Google searches are currently a primary means by which workers and other members of the public seek information about their lives and their world.  Every effort must be made to combat this serious infringement on the basic rights of freedom of speech and freedom of press.

After NBC News on Wednesday published a trove of leaked documents that show how Facebook "treated user data as a bargaining chip with external app developers," White House hopeful Sen. Bernie Sanders declared that it is time "to break Facebook up."

When British investigative journalist Duncan Campbell first shared the trove of documents with a handful of media outlets including NBC News in April, journalists Olivia Solon and Cyrus Farivar reported that "Facebook CEO Mark Zuckerberg oversaw plans to consolidate the social network's power and control competitors by treating its users' data as a bargaining chip, while publicly proclaiming to be protecting that data." With the publication Wednesday of nearly 7,000 pages of records—which include internal Facebook emails, web chats, notes, presentations, and spreadsheets—journalists and the public can now have a closer look at exactly how the company was using the vast amount of data it collects when it came to bargaining with third parties.

According to Solon and Farivar of NBC: Taken together, they show how Zuckerberg, along with his board and management team, found ways to tap Facebook users' data—including information about friends, relationships, and photos—as leverage over the companies it partnered with. In some cases, Facebook would reward partners by giving them preferential access to certain types of user data while denying the same access to rival companies. For example, Facebook gave Amazon special access to user data because it was spending money on Facebook advertising. In another case the messaging app MessageMe was cut off from access to data because it had grown too popular and could compete with Facebook.

Content creators everywhere are starting to panic about an upcoming policy change over at YouTube that threatens to eliminate all accounts and channels on the Google-owned video platform that are deemed to no longer be “commercially viable.” In the “Account Suspension & Termination” section of YouTube’s “Terminations by YouTube for Service Changes,” guidelines, the company explains that, as of December 10, 2019, “YouTube may terminate your access, or your Google account’s access to all or part of the Service, if YouTube believes, in its sole discretion, that provision of the Service to you is no longer commercially viable.”