Comment Period Ends for Potential Colorado Privacy Act Universal Opt-Out Mechanisms

On December 13, 2023, the Colorado Attorney General’s Office closed the comment period for its proposed short-list of potential universal opt-mechanisms (UOOMs) that allegedly meet the technical and legal specifications described in the Colorado Privacy Act (CPA). The CPA prohibits opt-out mechanisms that are a “default setting” and instead requires signals to represent a consumer’s “affirmative, freely given, and unambiguous” choice to opt out.

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