Services US Privacy Section - SmartyAds (original) (raw)

Last updated: 29 April 2025

This section offers additional details specifically for residents of certain U.S. states with unique data privacy laws and regulations. These laws may confer specific rights to residents of these states when they become effective.

We appoint Data Protection Officers to ensure compliance with applicable data protection laws when processing personal information. To contact the Data Protection Officer directly, please email dpo@smartyads.com or visit “Your Privacy Choices” form in the footer of this page.

California Privacy Notice

California Privacy Rights (CCPA)

If you are a resident of California, you are entitled to additional privacy rights under the California Consumer Privacy Act (CCPA). We are committed to respecting your privacy and handling your personal information with transparency and care. This section describes your rights and explains how you can exercise them.

1.Your Privacy Rights

As a California resident, you have the following rights:

Right to Know

You have the right to request that we disclose:

The categories of personal information we collect about you.
The categories of sources from which the personal information is collected.
The business or commercial purposes for collecting, sharing, or selling personal information.
The categories of third parties to whom we disclose personal information.
The specific pieces of personal information we have collected about you.

Right to Delete

You may request the deletion of personal information we have collected from you, subject to certain exceptions (e.g., legal obligations, security purposes, completing transactions, etc.).

Right to Correct

You may request that we correct inaccurate personal information that we maintain about you.

Under the California Consumer Privacy Act (CCPA), California residents have the right to opt out of the sale or sharing of their personal information.

Although SmartyAds does not sell personal information in the traditional sense (e.g., in exchange for money), certain data practices involving cookies, device identifiers, and advertising technology may be considered a “sale” or “sharing” under California law—particularly when personal information is disclosed for cross-context behavioral advertising or interest-based targeting.

Platforms Covered:

This right applies to personal information collected or transmitted through our websites and platforms, including:

ssp.smartyads.com (Supply-Side Platform);
dsp.smartyads.com (Demand-Side Platform);
exchange.smartyads.com (Ad Exchange).

How to Opt-Out

You can opt out of the sale or sharing of your personal information at any time by taking one of the following steps:

1. Use the “Your Privacy Choices” Form

Click the Your Privacy Choices form available in the footer of your SmartyAds user account (on ssp.smartyads.com or dsp.smartyads.com). Please note that our Ad Exchange platform does not provide any registration option and is only managed by us.

Our CMP solution, powered by Clym, allows users to manage their privacy preferences and control which types of cookies and trackers are active. You can access these settings through the cookie banner.

3. Send Us a Request

Alternatively, you may submit a request to opt out by contacting us directly:

Email: dpo@smartyads.com or through the Your Privacy Choices form.

Please include sufficient detail (e.g., your name, email address) to help us locate your records and apply your opt-out request properly. With respect to personal information collected about you via the Services, in order to accurately process and honor your opt-out request across all systems, we need you to provide us with the identifiers associated with each of your devices and browsers. Because our services operate across multiple environments, submitting all relevant identifiers helps us correctly match your request to any data that may be present in the advertising bid stream. Providing your name and email address alone will not enable us to do this.

The Your Privacy Choices form gives you the option to voluntarily submit your IP address, user agent, and/or mobile advertising identifier, and provides instructions for locating these identifiers on your devices. Without these identifiers, we may be unable to fully apply your opt-out on all devices or prevent future data from being associated with you. We will use your identifiers solely for the purpose of effectuating your opt-out request, and will retain your identifiers for this purpose on a going-forward basis until you make a “Right to Delete” request to have this information removed from our systems.

4. Global Privacy Control (GPC)

We also honor browser-based Global Privacy Control (GPC) signals. If your browser or extension sends a GPC signal, our systems will treat it as a valid opt-out request.

5. Opting Out Through a First Party (e.g., Website or CMP)

You may also exercise your opt-out rights through the first party that collects your personal information, such as the website you visit or a Consent Management Platform (CMP). These first parties may present you with privacy choices, including the option to opt out of the sale or sharing of your personal information.

When such a party communicates your preference to us—for example, through a bid request—we will honor your request accordingly. Once received, we will no longer sell or share your personal information with respect to that third party. Your privacy choices will be respected in accordance with applicable privacy laws and industry standards. Be advised that you must exercise your opt-out rights with each first-party website that you visit, as such opt-outs may not extend to other parties.

Please also read carefully Section the “Your Choices to Avoid Targeted Advertising” in the Services Privacy Policy.

What Happens When You Opt Out

When you opt out:

We will no longer “sell” or “share” your personal information for purposes of cross-context behavioral advertising.
We may still use your personal information for other business purposes permitted under CCPA, such as providing services you request, fraud prevention, and maintaining security.

Please note that due to the way that our services function, unless you provide us with your device identifiers (IP address, user agent, and mobile advertising identifier) in accordance with the section “Send Us a Request” above, we may not be able to associate your request with any Service Data. This is because we do not retain any user-level data in the form of identifiable personal data after an ad has been delivered . However, we will process your request to the extent feasible for both Website Data and Service Data in our systems.

Right to Limit Use and Disclosure of Sensitive Personal Information

If we receive sensitive personal information—such as precise geolocation data—from a first party (e.g., a website or Consent Management Platform (CMP) you interact with), you, as a California resident, have the right under the CCPA to limit the use and disclosure of such information to what is necessary to perform the services or provide the goods reasonably expected by an average consumer.

You may not interact directly with SmartyAds in connection with the personal information collected through our services, as such data is typically provided to us by first parties who have a direct relationship with you. However, if you exercise your right to limit the use of your sensitive personal information—either through a first party interface or via an LMT (Limit the Use of My Sensitive Personal Information) signal—we will honor that request in accordance with the CCPA.

In such cases, we will not use your sensitive personal information for targeted advertising or any secondary purposes beyond what is necessary to operate our services.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. This includes denying services, charging different prices, or providing a different level of quality based on your privacy choices.

2. How We Process and Use Personal Information

SmartyAds collects personal information in connection with our advertising technologies and services. This may include:

Identifiers such as IP addresses and mobile advertising IDs.
Geolocation information (such as city-level location derived from IP address).
Internet or other electronic network activity information (e.g., device type, browser type, interaction with ads).

We do not knowingly collect personal information from children under the age of 16.

3. How to Exercise Your Rights

To make a request under the CCPA, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)
Your browser or in-app identifier (optional), including:
- IP address and User-Agent, and/or
- Mobile advertising identifier (IDFA or AAID)

With the exception of opt-out requests (for which verification is, in most circumstances, not required) we may take steps to verify your identity before responding to your request to protect your privacy and the security of your data. Verification may include matching information you provide with information already in our systems.

You may authorize someone to submit a request on your behalf. With the exception of opt-out requests, if you use an authorized agent, we require:

A signed written authorization from you.
Direct verification of your identity, unless your agent holds a valid power of attorney under the California Probate Code.

5. Data Retention

We retain personal information only for as long as is reasonably necessary for the purposes described in our Services Privacy Policy. Retention periods may vary depending on the nature of the data and the context in which it was collected.

This California Privacy Notice is effective as of January 7, 2026.

Data Protection Rights of The Residents of Virginia and Colorado

SmartyAds is committed to adhering to the guidelines and standards for data processing outlined in the Colorado Consumer Data Protection Act (CPA), as well as the Virginia Consumer Data Protection Act (VCDPA). Under these legislation you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected.
Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

We may take steps to verify your identity before responding to your request to protect your privacy and the security of your data. Verification may include matching information you provide with information already in our systems.

If the processing of your personal information falls under this law and your request is declined, you have the right to appeal the decision. You can appeal by replying directly to the email you received regarding your request. Additionally, you may have the right to file a complaint with the Attorney General regarding the outcome of your appeal. Contact the Attorney General for Virginia here and for Colorado here.

Connecticut Data Privacy Act (CTDPA)

Under the CTDPA, you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Delaware Personal Data Privacy Act (DPDA)

Under DPDA, you have specific rights concerning the handling of your personal information, in particular:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Florida Digital Bill of Rights (FDBR)

Under FDBR, you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Indiana Consumer Data Protection Act (CDPA)

Under CDPA, you have specific rights regarding the handling of your personal information, in particular:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Iowa Act Relating to Consumer Data Protection (ICDPA)

Under ICDPA, you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Montana Consumer Data Privacy Act (MCDPA)

Under MCDPA, you have specific rights regarding the handling of your personal information, in particular:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Oregon Consumer Privacy Act (OCPA)

Under OCPA, you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Utah Consumer Privacy Act (UTCPA)

Under UTCPA, you have specific rights regarding the handling of your personal information, in particular:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Tennessee Information Protection Act (TIPA)

Under TIPA, you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Texas Data Privacy and Security Act (TDPSA)

Under TDPSA, you have specific rights regarding the handling of your personal information:

You can request access to the personal information we hold about you, or ask for it to be updated or corrected. Depending on the applicable laws, you may have additional rights related to your personal information.
You have the right to obtain your personal information in a usable format and transfer it to another party, known as the right to data portability.
You can request the deletion of the personal information we hold about you.
You can opt out of certain types of personal information processing, such as targeted advertising and the sale of your personal information.

To exercise any of your data rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)

Minnesota Consumer Data Privacy Act (MCDPA)

Under the Minnesota Consumer Data Privacy Act (MCDPA), you have specific rights regarding the handling of your personal information:

You may request access to the personal information we hold about you and request that it be corrected if it is inaccurate.

You have the right to obtain your personal information in a portable and readily usable format and to transfer it to another organization.

You may request the deletion of the personal information we hold about you.

You may opt out of certain types of personal data processing, including targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise your Minnesota privacy rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)
Your browser or in-app identifier (optional), including:
- IP address and User-Agent, and/or
- Mobile advertising identifier (IDFA or AAID)

We may take reasonable steps to verify your identity before responding to your request.

If your request is denied, you may appeal by replying to the email you receive regarding your request. If your appeal is denied, you may submit a complaint to the Minnesota Attorney General.

Maryland Online Data Privacy Act (MODPA)

Under the Maryland Online Data Privacy Act (MODPA), you have specific rights regarding the handling of your personal information:

You may request access to the personal information we hold about you and request that it be corrected.

You have the right to obtain your personal information in a portable and usable format.

You may request the deletion of the personal information we hold about you.

You may opt out of certain types of personal data processing, including targeted advertising, the sale of personal data, and profiling.

To exercise your Maryland privacy rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)
Your browser or in-app identifier (optional), including:
- IP address and User-Agent, and/or
- Mobile advertising identifier (IDFA or AAID)

We may take reasonable steps to verify your identity before responding to your request.

If your request is denied, you may appeal by replying to the email you received. If your appeal is denied, you may submit a complaint to the Maryland Attorney General.

Kentucky Consumer Data Protection Act (KCDPA)

Under the Kentucky Consumer Data Protection Act (KCDPA), you have specific rights regarding the handling of your personal information:

You may request access to the personal information we hold about you and request that it be corrected.

You have the right to obtain your personal information in a portable and usable format.

You may request the deletion of the personal information we hold about you.

You may opt out of certain types of personal data processing, including targeted advertising, the sale of personal data, and profiling.

To exercise your Kentucky privacy rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)
Your browser or in-app identifier (optional), including:
- IP address and User-Agent, and/or
- Mobile advertising identifier (IDFA or AAID)

We may take reasonable steps to verify your identity before responding to your request.

If your request is denied, you may appeal by replying to the email you receive. If your appeal is denied, you may submit a complaint to the Kentucky Attorney General.

Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA)

Under the Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA), you have specific rights regarding the handling of your personal information:

You may request access to the personal information we hold about you and request that it be corrected.

You have the right to obtain your personal information in a portable and usable format.

You may request the deletion of the personal information we hold about you.

You may opt out of certain types of personal data processing, including targeted advertising, the sale of personal data, and profiling.

To exercise your Rhode Island privacy rights, you can contact us in one of the following ways:

Email: dpo@smartyads.com

Regular Mail: SmartyAds Inc., 1201 N. Orange Street, Suite 762, Wilmington, New Castle County, DE 19801

Your Privacy Choices form

To help us process your request, please provide:

Your full name
The email address associated with your interactions with us
The nature of your request (e.g. do not sell or share my personal information)
Your browser or in-app identifier (optional), including:
- IP address and User-Agent, and/or
- Mobile advertising identifier (IDFA or AAID)

We may take reasonable steps to verify your identity before responding to your request.

If your request is denied, you may appeal by replying to the email you receive. If your appeal is denied, you may submit a complaint to the Rhode Island Attorney General.

Contacts

United States

1201 N. Orange Street, Suite
762, Wilmington, New Castle
County, DE 19801
+1 516 243 1241

United Kingdom

102 Langdale House, 11
Marshalsea Road, London,
England, SE1 1EN
+44 208 089 8320

Cyprus

Markou Drakou, 64 PLAZA COURT
Office 23, Mesa Geitonia
4002, Limassol

support@smartyads.com
sales@smartyads.com

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Your Privacy Choices

The states of California, Colorado, Connecticut, Delaware, Iowa, Indiana, Montana, Maryland, Nebraska, Kentucky, Rhode Island, Nevada, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia, Minnesota, Tennessee have laws that allow users to request that SmartyAds refrain from selling their personal information or using it for targeted advertising.
Learn more at Website US Privacy Section and Services US Privacy Section

Submit a Privacy Choice

You, or the person you’re requesting information on behalf of, must live in one of these states in order for your request to be valid.

We collect personal data from you if you have visited our website (“Website Data”) or interact with our third-party advertising clients who collect information on other services not associated with SmartyAds (“Service Data”). We can promptly honor your privacy choices regarding Website Data. Due to the way that our services function, we may not always be able to associate your request with any Service Data because we do not retain all user-level data in the form of identifiable personal data after an ad has been delivered . However, you can submit your device identifiers to us and we will attempt to opt you out of future targeted advertising campaigns that we process when we see the identifiers you’ve provided. Click “Next” to proceed.

Thank You For Submitting
Your Request

Services US Privacy Section - SmartyAds (original) (raw)

California Privacy Notice

California Privacy Rights (CCPA)

1.Your Privacy Rights

Right to Know

Right to Delete

Right to Correct

How to Opt-Out

1. Use the “Your Privacy Choices” Form

2. Adjust Your Cookie Settings

3. Send Us a Request

4. Global Privacy Control (GPC)

5. Opting Out Through a First Party (e.g., Website or CMP)

What Happens When You Opt Out

Right to Limit Use and Disclosure of Sensitive Personal Information

Right to Non-Discrimination

2. How We Process and Use Personal Information

3. How to Exercise Your Rights

5. Data Retention

Data Protection Rights of The Residents of Virginia and Colorado

Connecticut Data Privacy Act (CTDPA)

Delaware Personal Data Privacy Act (DPDA)

Florida Digital Bill of Rights (FDBR)

Indiana Consumer Data Protection Act (CDPA)

Iowa Act Relating to Consumer Data Protection (ICDPA)

Montana Consumer Data Privacy Act (MCDPA)

Oregon Consumer Privacy Act (OCPA)

Utah Consumer Privacy Act (UTCPA)

Tennessee Information Protection Act (TIPA)

Texas Data Privacy and Security Act (TDPSA)

Minnesota Consumer Data Privacy Act (MCDPA)

Maryland Online Data Privacy Act (MODPA)

Kentucky Consumer Data Protection Act (KCDPA)

Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA)