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Consumer Reports comments to the Colorado Attorney General on rulemaking under the Colorado Privacy Act

Consumer Reports submitted comments to the Colorado Attorney General’s office in response to its call for input on proposed rulemaking under the new Colorado Privacy Act. In its comments, Consumer Reports recommends that the Attorney General:

  • Create a registry of valid Universal Opt-Out Mechanisms
  • Clarify the definitions of “sale” and “targeted advertising”
  • Strengthen the requirements for consent
  • Require companies to display opt-out status
  • Mandate transparency around algorithmic decisionmaking
  • Ban unsubstantiated claims about AI and the use of unexplainable algorithms that have significant legal effects
  • Apply consumer opt outs comprehensively online and offline for known users
  • Prohibit companies from retaliating against consumers who exercise their privacy rights