🏔️ Colorado Privacy Disclosures

Effective Date: February 18, 2026 | Last Updated: February 18, 2026

Colorado Privacy Act (CPA)

This page describes your privacy rights under the Colorado Privacy Act (CPA), which became effective July 1, 2023.

If you are a Colorado resident, you have specific rights regarding your personal data.

Your Colorado Privacy Rights

Right	Description	How to Exercise
Right to Access	Confirm whether we process your personal data and request access	Email: privacy@hotspot-us.com
Right to Delete	Request deletion of your personal data	Settings > Account > Delete Account
Right to Correct	Correct inaccuracies in your personal data	Settings > Profile > Edit Information
Right to Data Portability	Obtain your personal data in a portable, usable format	Email: privacy@hotspot-us.com
Right to Opt-Out of Sale	Opt-out of "sale" of personal data	NOT APPLICABLE - We don't sell your data
Right to Opt-Out of Targeted Advertising	Opt-out of processing for targeted advertising	NOT APPLICABLE - We don't use targeted advertising
Right to Opt-Out of Profiling	Opt-out of profiling with legal/significant effects	NOT APPLICABLE - We don't use profiling for decisions with legal effects

Personal Data We Collect

Identifiers: Email, username, device ID
Demographic Data: Age, gender, relationship status (self-reported)
Precise Geolocation: Venue check-in locations (NOT continuous GPS)
Commercial Information: Check-in history, promotion redemptions
Usage Data: App interactions, features used
Inferences: Preferences derived from check-in behavior

How We Use Your Data

Provide Services: Check-ins, Hot Sync, promotions, venue discovery
Personalization: Show relevant venues and deals
Analytics: Generate aggregated, anonymized venue statistics
Safety & Security: Fraud prevention, account security
Communications: Send transactional and promotional notifications

We Do NOT:

            ✅ Sell your personal data
✅ Use targeted advertising based on cross-site behavior
✅ Use profiling for decisions with legal or similarly significant effects
✅ Track continuous location (only venue check-ins)

        

Sensitive Data

Under the CPA, the following categories are considered sensitive data:

Precise Geolocation: We collect venue check-in locations (with your consent)
NOT COLLECTED: Racial/ethnic origin, religious beliefs, sexual orientation, citizenship status, genetic/biometric data, health diagnoses, financial account info, children's data

Consent: By using HotSpot, you consent to our processing of precise geolocation for check-in functionality. You may withdraw consent by deleting your account.

No Profiling with Legal Effects

HotSpot does NOT use profiling to make decisions that produce legal or similarly significant effects concerning you (e.g., credit, employment, housing, education, healthcare).

How to Exercise Your Rights

Submit a Request

Email: privacy@hotspot-us.com

Subject: "Colorado Privacy Request" or "CPA Request"

Include: Name, email, username, and specific right you wish to exercise

Response Timeline

45 days: We will respond within 45 days
Extension: May extend by 45 additional days (we will notify you)
Free: No charge for requests

Appeals Process

If we deny your request, you may appeal:

Email: privacy@hotspot-us.com with subject: "CPA Appeal"
We will respond within 45 days
If denied again, you may contact the Colorado Attorney General

Authorized Agents

You may use an authorized agent to submit requests. The agent must provide written authorization and proof of identity.

Universal Opt-Out Mechanism

Colorado law requires businesses to honor universal opt-out signals. HotSpot recognizes:

Global Privacy Control (GPC): If your browser sends a GPC signal, we will treat it as an opt-out request (where applicable)
Note: Since we don't sell data or use targeted advertising, GPC signals have limited applicability

Non-Discrimination

We will not discriminate against you for exercising your CPA rights.

Contact Information

For Colorado Privacy Requests:

Email: privacy@hotspot-us.com
Subject: "Colorado Privacy Request" or "CPA"
Mail: HotSpot, Inc., [Address TBD]