WHY WALLA

Understanding the Colorado Privacy Act (CPA): What SaaS Companies Like Walla Need to Know

Yuvin Kim

July 16, 2025

WHY WALLA

Understanding the Colorado Privacy Act (CPA): What SaaS Companies Like Walla Need to Know

Yuvin Kim

July 16, 2025

As of July 1, 2023, the Colorado Privacy Act (CPA) officially came into effect—making Colorado the third U.S. state (after California and Virginia) to enforce a comprehensive privacy law. For SaaS companies targeting U.S. users or expanding globally, CPA isn't just another regulation—it's a litmus test for trust, compliance, and scalable infrastructure design.

If you’re operating a service like Walla, which processes personal data across regions, understanding and complying with CPA is a key milestone in building a trustworthy SaaS product in the U.S. market.

1. What is CPA and Who Must Comply?

Item

Details

Name

Colorado Privacy Act (CPA)

Effective Date

July 1, 2023

Applicability

Businesses that either:

① Control or process data of 100,000+ Colorado residents annually


② Process data of 25,000+ residents and derive revenue from selling personal data


Targeted Data Subjects

Colorado residents (consumers)

Exemptions

Public entities, GLBA-covered financial institutions, HIPAA-covered healthcare providers, higher education institutions

Supervisory Authority

Attorney General of Colorado

📌 It’s not about the company size—it's about the volume and sensitivity of data processed.

2. Key Principles of the CPA

The CPA takes significant cues from GDPR and California’s CPRA. Here are the core rights and duties:

1) Consumer Rights

Colorado residents have the right to:

  • Access their data

  • Correct inaccurate data

  • Delete their personal data

  • Obtain a copy (Data Portability)

  • Opt-out of profiling, targeted advertising, and data sales

🧠 Unique to CPA: It allows consumers to opt out of automated profiling and decision-making, such as algorithmic pricing or behavioral targeting.

2) Prior Consent for Sensitive Data

Explicit opt-in consent is required before collecting or using:

  • Race, religion, sexual orientation, health data, geolocation, biometric data

  • Data from children under 13 (with COPPA alignment)

3) Purpose Limitation & Data Minimization
  • Data must be used only for specified purposes

  • Companies must avoid over-collection and define retention periods

4) Data Protection Impact Assessments (DPIAs)
  • Required for high-risk activities such as profiling, handling sensitive data, or targeted ads

  • DPIAs must be documented and available for audit

3. What Does CPA Mean for SaaS Companies?

For companies building user-centric SaaS tools, CPA calls for privacy by design—not just a privacy policy.

Example: How Walla Responds

Compliance Requirement

Walla’s Response

Opt-out Mechanism

Clear consent flow with toggles for data usage and marketing

Automated Processing Transparency

Transparent documentation of conditional workflows and user data usage

Prior Consent for Sensitive Data

Explicit collection purpose, scope, and retention shared with the user

Data Subject Requests

API-based user portal for data deletion, correction, and portability

DPIA Readiness

Walla’s data flow architecture is pre-documented for audit and compliance purposes

4. How CPA Compares to Other U.S. State Laws

Criteria

Colorado (CPA)

California (CPRA)

Virginia (VCDPA)

Opt-out Rights

O

O

O

Profiling Opt-out

O (fully supported)

Partial

Partial

Consent for Sensitive Data

Required

Required

Required

DPIA Obligation

O

X

X

Penalties

$20,000 per violation, up to $500,000

Up to $7,500 per violation

Similar level

Private Right of Action

X (no direct lawsuits)

X (but AG delegation possible)

X

📌 Colorado’s CPA is more aligned with GDPR than Virginia’s law and includes stronger requirements around profiling and DPIAs.

5. Why It Matters: Building for Compliance from the Ground Up

CPA is more than legal formality—it's a new benchmark for ethical SaaS design. Especially in vertical SaaS or data-first platforms like Walla, compliance should not be a patch—it must be an architectural foundation.

+ TL;DR: Walla’s CPA-Ready Architecture
  • Region-Specific Data Handling: U.S. customer data stored in appropriate locations (e.g., AWS U.S. regions)

  • Consent + Encryption + API Control: Fully integrated data rights management

  • Transparent Business Logic: Opt-in/out logic and usage flow documented and reviewable

  • Compliance at Scale: Modular setup enables adaptation to other state laws like Texas or Oregon as they emerge

Final Thoughts

The Colorado Privacy Act is part of a growing wave of U.S. state-level privacy regulations that mirror global standards like the GDPR. For global SaaS players, it’s a signal: future-proofing your platform starts with data governance and user trust.

SaaS companies that build privacy into the core—from infrastructure to product design—will not only avoid legal pitfalls, but also win long-term customer loyalty in an increasingly privacy-conscious market.

https://home.walla.my

As of July 1, 2023, the Colorado Privacy Act (CPA) officially came into effect—making Colorado the third U.S. state (after California and Virginia) to enforce a comprehensive privacy law. For SaaS companies targeting U.S. users or expanding globally, CPA isn't just another regulation—it's a litmus test for trust, compliance, and scalable infrastructure design.

If you’re operating a service like Walla, which processes personal data across regions, understanding and complying with CPA is a key milestone in building a trustworthy SaaS product in the U.S. market.

1. What is CPA and Who Must Comply?

Item

Details

Name

Colorado Privacy Act (CPA)

Effective Date

July 1, 2023

Applicability

Businesses that either:

① Control or process data of 100,000+ Colorado residents annually


② Process data of 25,000+ residents and derive revenue from selling personal data


Targeted Data Subjects

Colorado residents (consumers)

Exemptions

Public entities, GLBA-covered financial institutions, HIPAA-covered healthcare providers, higher education institutions

Supervisory Authority

Attorney General of Colorado

📌 It’s not about the company size—it's about the volume and sensitivity of data processed.

2. Key Principles of the CPA

The CPA takes significant cues from GDPR and California’s CPRA. Here are the core rights and duties:

1) Consumer Rights

Colorado residents have the right to:

  • Access their data

  • Correct inaccurate data

  • Delete their personal data

  • Obtain a copy (Data Portability)

  • Opt-out of profiling, targeted advertising, and data sales

🧠 Unique to CPA: It allows consumers to opt out of automated profiling and decision-making, such as algorithmic pricing or behavioral targeting.

2) Prior Consent for Sensitive Data

Explicit opt-in consent is required before collecting or using:

  • Race, religion, sexual orientation, health data, geolocation, biometric data

  • Data from children under 13 (with COPPA alignment)

3) Purpose Limitation & Data Minimization
  • Data must be used only for specified purposes

  • Companies must avoid over-collection and define retention periods

4) Data Protection Impact Assessments (DPIAs)
  • Required for high-risk activities such as profiling, handling sensitive data, or targeted ads

  • DPIAs must be documented and available for audit

3. What Does CPA Mean for SaaS Companies?

For companies building user-centric SaaS tools, CPA calls for privacy by design—not just a privacy policy.

Example: How Walla Responds

Compliance Requirement

Walla’s Response

Opt-out Mechanism

Clear consent flow with toggles for data usage and marketing

Automated Processing Transparency

Transparent documentation of conditional workflows and user data usage

Prior Consent for Sensitive Data

Explicit collection purpose, scope, and retention shared with the user

Data Subject Requests

API-based user portal for data deletion, correction, and portability

DPIA Readiness

Walla’s data flow architecture is pre-documented for audit and compliance purposes

4. How CPA Compares to Other U.S. State Laws

Criteria

Colorado (CPA)

California (CPRA)

Virginia (VCDPA)

Opt-out Rights

O

O

O

Profiling Opt-out

O (fully supported)

Partial

Partial

Consent for Sensitive Data

Required

Required

Required

DPIA Obligation

O

X

X

Penalties

$20,000 per violation, up to $500,000

Up to $7,500 per violation

Similar level

Private Right of Action

X (no direct lawsuits)

X (but AG delegation possible)

X

📌 Colorado’s CPA is more aligned with GDPR than Virginia’s law and includes stronger requirements around profiling and DPIAs.

5. Why It Matters: Building for Compliance from the Ground Up

CPA is more than legal formality—it's a new benchmark for ethical SaaS design. Especially in vertical SaaS or data-first platforms like Walla, compliance should not be a patch—it must be an architectural foundation.

+ TL;DR: Walla’s CPA-Ready Architecture
  • Region-Specific Data Handling: U.S. customer data stored in appropriate locations (e.g., AWS U.S. regions)

  • Consent + Encryption + API Control: Fully integrated data rights management

  • Transparent Business Logic: Opt-in/out logic and usage flow documented and reviewable

  • Compliance at Scale: Modular setup enables adaptation to other state laws like Texas or Oregon as they emerge

Final Thoughts

The Colorado Privacy Act is part of a growing wave of U.S. state-level privacy regulations that mirror global standards like the GDPR. For global SaaS players, it’s a signal: future-proofing your platform starts with data governance and user trust.

SaaS companies that build privacy into the core—from infrastructure to product design—will not only avoid legal pitfalls, but also win long-term customer loyalty in an increasingly privacy-conscious market.

https://home.walla.my

As of July 1, 2023, the Colorado Privacy Act (CPA) officially came into effect—making Colorado the third U.S. state (after California and Virginia) to enforce a comprehensive privacy law. For SaaS companies targeting U.S. users or expanding globally, CPA isn't just another regulation—it's a litmus test for trust, compliance, and scalable infrastructure design.

If you’re operating a service like Walla, which processes personal data across regions, understanding and complying with CPA is a key milestone in building a trustworthy SaaS product in the U.S. market.

1. What is CPA and Who Must Comply?

Item

Details

Name

Colorado Privacy Act (CPA)

Effective Date

July 1, 2023

Applicability

Businesses that either:

① Control or process data of 100,000+ Colorado residents annually


② Process data of 25,000+ residents and derive revenue from selling personal data


Targeted Data Subjects

Colorado residents (consumers)

Exemptions

Public entities, GLBA-covered financial institutions, HIPAA-covered healthcare providers, higher education institutions

Supervisory Authority

Attorney General of Colorado

📌 It’s not about the company size—it's about the volume and sensitivity of data processed.

2. Key Principles of the CPA

The CPA takes significant cues from GDPR and California’s CPRA. Here are the core rights and duties:

1) Consumer Rights

Colorado residents have the right to:

  • Access their data

  • Correct inaccurate data

  • Delete their personal data

  • Obtain a copy (Data Portability)

  • Opt-out of profiling, targeted advertising, and data sales

🧠 Unique to CPA: It allows consumers to opt out of automated profiling and decision-making, such as algorithmic pricing or behavioral targeting.

2) Prior Consent for Sensitive Data

Explicit opt-in consent is required before collecting or using:

  • Race, religion, sexual orientation, health data, geolocation, biometric data

  • Data from children under 13 (with COPPA alignment)

3) Purpose Limitation & Data Minimization
  • Data must be used only for specified purposes

  • Companies must avoid over-collection and define retention periods

4) Data Protection Impact Assessments (DPIAs)
  • Required for high-risk activities such as profiling, handling sensitive data, or targeted ads

  • DPIAs must be documented and available for audit

3. What Does CPA Mean for SaaS Companies?

For companies building user-centric SaaS tools, CPA calls for privacy by design—not just a privacy policy.

Example: How Walla Responds

Compliance Requirement

Walla’s Response

Opt-out Mechanism

Clear consent flow with toggles for data usage and marketing

Automated Processing Transparency

Transparent documentation of conditional workflows and user data usage

Prior Consent for Sensitive Data

Explicit collection purpose, scope, and retention shared with the user

Data Subject Requests

API-based user portal for data deletion, correction, and portability

DPIA Readiness

Walla’s data flow architecture is pre-documented for audit and compliance purposes

4. How CPA Compares to Other U.S. State Laws

Criteria

Colorado (CPA)

California (CPRA)

Virginia (VCDPA)

Opt-out Rights

O

O

O

Profiling Opt-out

O (fully supported)

Partial

Partial

Consent for Sensitive Data

Required

Required

Required

DPIA Obligation

O

X

X

Penalties

$20,000 per violation, up to $500,000

Up to $7,500 per violation

Similar level

Private Right of Action

X (no direct lawsuits)

X (but AG delegation possible)

X

📌 Colorado’s CPA is more aligned with GDPR than Virginia’s law and includes stronger requirements around profiling and DPIAs.

5. Why It Matters: Building for Compliance from the Ground Up

CPA is more than legal formality—it's a new benchmark for ethical SaaS design. Especially in vertical SaaS or data-first platforms like Walla, compliance should not be a patch—it must be an architectural foundation.

+ TL;DR: Walla’s CPA-Ready Architecture
  • Region-Specific Data Handling: U.S. customer data stored in appropriate locations (e.g., AWS U.S. regions)

  • Consent + Encryption + API Control: Fully integrated data rights management

  • Transparent Business Logic: Opt-in/out logic and usage flow documented and reviewable

  • Compliance at Scale: Modular setup enables adaptation to other state laws like Texas or Oregon as they emerge

Final Thoughts

The Colorado Privacy Act is part of a growing wave of U.S. state-level privacy regulations that mirror global standards like the GDPR. For global SaaS players, it’s a signal: future-proofing your platform starts with data governance and user trust.

SaaS companies that build privacy into the core—from infrastructure to product design—will not only avoid legal pitfalls, but also win long-term customer loyalty in an increasingly privacy-conscious market.

https://home.walla.my

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The form you've been searching for?

Walla, Obviously.

Paprika Data Lab Inc.

557, Yeoksam-ro, Gangnam-gu, Seoul

The form you've been searching for?

Walla, Obviously.

Paprika Data Lab Inc.

557, Yeoksam-ro, Gangnam-gu, Seoul

The form you've been searching for?

Walla, Obviously.

Paprika Data Lab Inc.

557, Yeoksam-ro, Gangnam-gu, Seoul