By: Linda L. Goodman
The Colorado Privacy Act (“CPA”) contains express Consumer rights, including the rights of Colorado Consumers to opt-out of the Sale of Personal Data and the Processing of Personal Data for Targeted Advertising. Beginning on July 1, 2024, organizations that fall within the CPA’s application thresholds must allow Consumers to opt-out of the Sale of their Personal Data or use of their Personal Data for Targeted Advertising using a Universal Opt-Out Mechanism (“UOOM”).
To ensure that Consumers and Controllers know which UOOMs will be enforced in Colorado, CPA Rule 5.07 explains that the Attorney General will “maintain a public list of Universal Opt-Out Mechanisms that have been recognized to meet the standards of this subsection,” and that the list “shall be released no later than January 1, 2024, and shall be updated periodically.”
The Colorado Department of Law (“The Department”) accepted applications for UOOMs from October 5 – November 6, 2023, and selected a narrow list of potential UOOMs for consideration (the “shortlist”). The Department accepted public comment on the shortlist of UOOMs and their accompanying applications through December 14, 2023. The Department considered public comments alongside each application and the criteria outlined in the UOOM application when deciding the final list.
The below list of UOOMs includes those The Department considers valid under the CPA and its regulations.
| Universal Opt-Out Mechanism | Technical Specification | Additional Information |
| Global Privacy Control (“GPC”) | Privacy CG | Website: Global Privacy Control |
| Global Privacy Control Implementation Guide |
The Department notes that this list does not exclude additional UOOMs from meeting the requirements of the CPA and its regulations now or in the future. This list represents the valid and recognized UOOMs that The Department will prioritize for enforcement. As noted in Rule 5.07, the list shall be updated periodically. The Department may update the list to include new UOOMs or remove UOOMs which are no longer compliant. When The Department updates the list, it will accept new applications and seek public comment.
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This article is a publication of The Goodman Law Firm and is intended to provide information on recent legal developments and it is not intended to be and should not be relied on as legal advice for any particular matter. This article does not create an attorney-client relationship, nor should it be construed as legal advice or an opinion on specific situations. This may constitute “Attorney Advertising” under the Rules of Professional Conduct and under the law of other jurisdictions.
Linda L. Goodman is the founder of The Goodman Law Firm, concentrating its practice in internet business and law. Her firm’s clients include Advertisers, Affiliates, Affiliate Networks, and ISP’s.
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