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Colorado Privacy Act Consumer Rights & How to Use Them

Independently fact-checked against primary sources (last audited August 14, 2026). · Reviewed by the RecordingLaw editorial team. · Law checked current as of August 14, 2026. How we verify our legal content

Colorado Privacy Act Consumer Rights & How to Use Them

Frequently Asked Questions

Does Colorado require every website to honor the Global Privacy Control?

Only covered controllers qualify: those processing data of at least 100,000 Colorado consumers per year, or 25,000 consumers and deriving revenue or a price discount from selling personal data (there is no minimum-percentage-of-revenue threshold), and controllers that process biometric identifiers are covered regardless of volume since July 1, 2025. Small websites with minimal Colorado users are exempt. For sites that do qualify, honoring GPC has been mandatory since July 1, 2024, under C.R.S. section 6-1-1306(1)(a)(IV)(B). Virginia, by contrast, has no such requirement under its VCDPA.

What is the difference between opting out of sale and opting out of targeted advertising under the CPA?

A sale under the CPA is an exchange of your personal data for monetary consideration: money actually changes hands. Targeted advertising is broader and covers using your cross-site or cross-app behavioral data to serve you ads even if your data was not sold. The Global Privacy Control opts you out of both purposes automatically. You can also opt out of each separately through a company's direct opt-out links.

Can I submit a CPA request through an authorized agent?

Yes. Under 4 CCR 904-3 Rule 4.03, an authorized agent may submit opt-out requests on your behalf. The company may verify the agent's authority using commercially reasonable methods. For other rights such as access, deletion, and correction, the Rules similarly permit authorized agents subject to identity and authority verification.

How long does a company have to respond to my CPA appeal?

45 days from the date the company receives your appeal, under C.R.S. section 6-1-1306(3)(b). The company can extend by 60 additional days for complex cases, but must notify you before the original window closes. If the appeal is denied, the company must direct you to the Colorado AG's complaint process.

Does the CPA cover my employer's data about me as an employee?

Mostly no, with one significant biometric exception. The CPA defines consumer as a Colorado resident acting in a personal or household context, so data your employer holds about you in your capacity as an employee, including payroll records, HR files, and work communications, is excluded from the consumer rights described above. Since July 1, 2025, however, C.R.S. section 6-1-1314(6) regulates employer biometrics directly: your employer may require consent to collect your biometric identifier as a condition of employment only for secure-location or secure-system access, recording the start and end of your full work day, workplace safety or security, or public safety in an emergency or crisis. Any other use requires your separate consent, cannot be made a condition of employment, and your employer may not retaliate against you for refusing. Those protections cover prospective employees and, under the statute's definition of employee, contractors, subcontractors, interns, and fellows.

What happens if a company ignores my CPA request entirely?

Failing to respond within 45 days, or 90 days with a timely-noticed extension, is a violation of C.R.S. section 6-1-1306(2). Because there is no response to appeal, you can skip directly to filing a complaint with the Colorado Attorney General at coag.gov/file-a-complaint/data-privacy-data-breach/ or by calling 800-222-4444. Penalties may reach $20,000 per violation under Colorado's Consumer Protection Act.

Does Colorado have a private right of action for CPA violations?

No. Enforcement is exclusively by the Colorado Attorney General or district attorneys under C.R.S. section 6-1-1311. Individual consumers cannot sue a company directly for violating the CPA. Filing a complaint with the AG's Consumer Protection Section is the prescribed consumer escalation path.

Is my second CPA request really going to cost money?

It can. Your first request within a 12-month period is always free under C.R.S. section 6-1-1306(2). A second or subsequent request within the same 12-month period may be subject to a fee calculated under the Colorado Open Records Act rate: up to $0.25 per standard page for paper records. Importantly, no per-page fee applies when records are delivered digitally, and most companies respond electronically. If you need to submit multiple requests in a year, bundling them into a single comprehensive request keeps you in the free tier regardless of format.

Updates

Corrected the employment-context section and the related FAQ, which said the Colorado Privacy Act simply does not reach employee data: since July 1, 2025, C.R.S. 6-1-1314(6) limits when an employer may require biometric consent as a condition of employment and bars retaliation for refusing.

Corrected the Colorado Privacy Act's coverage test (there is no revenue-percentage threshold; any sale-derived revenue at the 25,000-consumer tier counts, and any biometric-data processing is separately covered), fixed the statute citations for the anti-discrimination rule and the July 1, 2024 opt-out-signal mandate, corrected the description of California's opt-out-signal law as mandatory rather than voluntary, added the exclusively-online exception to the two-submission-method rule, and corrected the sensitive-data list (citizenship terminology, genetic and biological data categories, and the geolocation radius figure).

Independently fact-checked against the cited primary sources; governing law re-checked for recent changes

Corrected the Data Portability section: C.R.S. 6-1-1306(1)(e) caps the portability right at two exercises per calendar year, a hard limit independent of fees. The page previously implied unlimited portability requests as long as delivery was digital.

Governing law re-checked for recent changes

Reviewed and approved by an editor

Sources and References

  1. C.R.S. section 6-1-1306. Consumer personal data rights (SB 21-190)(leg.colorado.gov)
  2. 4 CCR 904-3 Rule 4.02. Submitting Requests to Exercise Personal Data Rights(law.cornell.edu)
  3. 4 CCR 904-3 Rule 4.03. Right to Opt Out(law.cornell.edu)
  4. 4 CCR 904-3 Rule 4.04. Right of Access(law.cornell.edu)
  5. 4 CCR 904-3 Rule 4.05. Right to Correction(law.cornell.edu)
  6. 4 CCR 904-3 Rule 4.06. Right to Deletion(law.cornell.edu)
  7. 4 CCR 904-3 Rule 4.07. Right to Data Portability(law.cornell.edu)
  8. 4 CCR 904-3 Rule 4.08. Authentication(law.cornell.edu)
  9. 4 CCR 904-3 Rule 4.09. Responding to Consumer Requests(law.cornell.edu)
  10. 4 CCR 904-3 Rule 5.03. Notice and Choice for Universal Opt-Out Mechanisms(law.cornell.edu)
  11. 4 CCR 904-3 Rule 7.02. Required Consent(law.cornell.edu)
  12. 4 CCR 904-3 Rule 9.03. Profiling Opt-Out Transparency(law.cornell.edu)
  13. 4 CCR 904-3 Rule 9.04. Opting Out of Profiling in Furtherance of Decisions That Produce Legal or Similarly Significant Effects(law.cornell.edu)
  14. Colorado AG. Universal Opt-Out and the Colorado Privacy Act (UOOM Registry)(coag.gov)
  15. Colorado AG. File a Complaint: Data Privacy and Data Breach(coag.gov)
  16. SB 24-041. Privacy Protections for Children's Online Data (signed May 31, 2024; effective October 1, 2025)(leg.colorado.gov)
  17. HB 24-1130 (signed act). C.R.S. section 6-1-1314, biometric identifiers and biometric data, including subsection (6) use of consent by employers; effective July 1, 2025(content.leg.colorado.gov)
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