Colorado Privacy Act duties when engineers in Türkiye touch your data
The Colorado Privacy Act (SB21-190) has applied since July 1, 2023 to controllers that do business in the state or target its residents and either control or process the personal data of 100,000 or more of its consumers in a calendar year, or earn revenue or discounts from selling personal data while processing the data of 25,000 or more. If your company is in scope and we work on systems holding that data, we act as your processor, and the Act requires a contractually binding processing agreement setting out each side's obligations. The controller also runs data protection assessments before selling personal data or processing sensitive data, answers consumer requests within 45 days (extendable by 45), and since July 1, 2024 has had to honor universal opt-out mechanisms such as Global Privacy Control. Only the Attorney General and district attorneys enforce it. As of October 5, 2026 no comprehensive federal consumer privacy law is in force.





