The Connecticut Data Privacy Act (CTDPA, Public Act No. 22-15) has two specific requirements for sites that process personal data for targeted advertising or sell personal data.

This page covers one piece of the picture. For the full scope of the CTDPA — who must comply, the thresholds, the consumer rights and the penalties — start with our complete guide to the CTDPA and cookies.

The first is immediate: a clear and conspicuous link on the site to an opt-out page.

The second took effect on January 1, 2025: the obligation to honor opt-out signals sent by platforms, technologies, or mechanisms with consumer consent, such as the Global Privacy Control (GPC).

This article focuses exclusively on what the CTDPA requires from a Cookies Policy: what must be in the document, how consent and opt-out must work, and what the law's specific requirements mean for each tracker on your site.

The cookie banner is the visual consent interface. It is what the visitor sees when they first access the site.

The Cookies Policy is the detailed document. It is where the user finds complete information about each technology: what it collects, what it is for, who receives the data, and how to exercise rights.

Both need to exist. Both need to be aligned. And the Cookies Policy must be accessible from a clear link within the consent notice itself.

Section 6(a)(1) requires the controller to limit collection to what is adequate, relevant, and reasonably necessary for the disclosed purposes. And Section 6(c)(2) requires the purpose to be in the privacy notice.

For cookies, each tracker category needs a specific purpose description, not a generic one.

What does not work: "cookies to improve your experience."

What works: "Analytics cookies: collect browsing behavior data including pages visited, traffic source, and session duration. Used to identify content improvement opportunities. Data is not sold or used for targeted advertising."

"Advertising cookies: collect behavioral identifiers shared with advertising platforms for targeted advertising on non-affiliated websites. Include pixels from Meta Ads and Google Ads. Consumers may exercise opt-out via the opt-out link on this page."

The Policy must list tracker categories:

Necessary cookies: essential for basic functionality. Do not constitute targeted advertising or data sale. Must be documented but do not require opt-out.

Analytics cookies: depends on configuration. If data stays internal, generally does not constitute targeted advertising. If sent to third parties for targeting on other sites, may qualify.

Advertising cookies: almost always constitute "targeted advertising" under the CTDPA, which defines it as ads based on data "obtained or inferred from the consumer's activities over time and across nonaffiliated Internet web sites or online applications" (Section 1(28)).

Functional cookies: remember preferences. Generally do not constitute targeted advertising or sale.

Third-party cookies: fired by external services. Correct tag categorization is what makes accurate documentation possible.

The CTDPA defines targeted advertising (Section 1(28)) as displaying ads based on personal data obtained or inferred from the consumer's activities over time and across nonaffiliated Internet web sites or online applications.

What does not constitute targeted advertising:

Advertisements based on activities within the controller's own websites or online applications.

Advertisements based on the context of a current search query or visit.

Advertisements directed to a consumer in response to an information request.

Processing personal data solely to measure or report advertising frequency, performance, or reach.

Retargeting campaigns using behavioral data from other sites therefore almost always constitute targeted advertising under the CTDPA.

The CTDPA defines sale (Section 1(26)) as the exchange of personal data for monetary or other valuable consideration by the controller to a third party.

Not a sale: disclosure to processors, disclosure for products/services requested by the consumer, disclosure to affiliates, consumer-directed disclosure, publicly made available data, and M&A transfers.

If the site shares data with partners in exchange for services or other economic benefits, it may constitute a sale even without direct cash payment.

The Policy must identify the categories of third parties receiving data via cookies (Section 6(c)(5)).

This includes digital advertising platforms, analytics tools, programmatic advertising networks, email marketing platforms receiving behavioral data, and any other partner receiving identifiers or user behaviors collected via cookie.

The obligation to limit collection to what is necessary (Section 6(a)(1)) implies data should also be retained only for as long as necessary. The Cookies Policy must document how long each cookie category stays active and how long data is retained in systems.

Section 6(e)(1)(A)(i) requires a clear and conspicuous link on the controller's website to a page enabling the consumer or their agent to opt out of targeted advertising or sale of personal data.

This link must be visible on the page, not in obscure locations. The Cookies Policy must identify this link and describe how the opt-out works.

Section 6(e)(1)(A)(ii) requires that from January 1, 2025, controllers processing for targeted advertising or selling data allow opt-out via signal sent with consumer consent.

In practical terms for cookies: when a user visits the site with the GPC activated in their browser, the site must interpret this signal as an opt-out of targeted advertising and data sale, and automatically block the corresponding trackers.

The mechanism must meet CTDPA-specific requirements (Section 6(e)(1)(A)(ii)):

Cannot unfairly disadvantage another controller.

Cannot be a default setting: must represent an affirmative, freely given, and unambiguous consumer choice.

Must be consumer-friendly and easy for the average consumer.

Must be as consistent as possible with similar mechanisms required by other laws.

Must enable the controller to accurately determine whether the consumer is a Connecticut resident.

When the opt-out signal conflicts with an existing controller-specific setting or loyalty program participation, the controller must comply with the signal but may notify the consumer of the conflict and give them the option to confirm their prior preference.

The Cookies Policy must describe how the site processes these signals.

Section 1(6) defines consent as a clear affirmative act signifying a consumer's freely given, specific, informed, and unambiguous agreement.

What is not valid consent:

Accepting general terms with data processing descriptions alongside unrelated information.

Hovering over, muting, pausing, or closing a piece of content.

Any agreement obtained through dark patterns.

Dark patterns are defined in Section 1(11) as interfaces designed or manipulated with the substantial effect of subverting or impairing user autonomy, decision-making, or choice, including any practice the FTC refers to as a dark pattern.

The correct standard for cookies: non-essential cookies off by default. The user chooses what to enable, not what to disable.

If the user granted consent for non-essential cookies and then decides to revoke, Section 6(a)(6) requires the controller to:

Provide a revocation mechanism at least as easy as the consent mechanism.

Cease processing not later than 15 days after receiving the revocation.

This 15-day deadline is exclusive to the CTDPA and means the consent management platform must be configured to process revocations promptly, not just log them.

Section 6(a)(7) prohibits processing data of consumers aged 13 to 15 for targeted advertising or sale without their consent when the controller has actual knowledge of that age range.

If the site may have users in this range, the Cookies Policy must describe how advertising cookies are blocked for this audience and how consent is obtained when required.

The CTDPA does not specify a minimum privacy notice update frequency like the CCPA/CPRA does. But Section 6(a)(2) prohibits processing for purposes not disclosed without consent, and Section 6(a)(1) requires limiting collection to what is necessary for the disclosed purposes.

In practice, situations requiring a Cookies Policy update:

Adding a new advertising pixel or tracker.

New analytics tool sending data to third parties.

New partner receiving behavioral data.

Change in the use of cookie data for new purposes.

Any modification to opt-out mechanisms.

Continuous data mapping is what keeps the cookie inventory synchronized with the document.

Violations are treated as unfair trade practices by the Connecticut Attorney General. There is no private right of action.

From January 2025, the cure period is discretionary. The AG may act without a guaranteed prior correction period.

AdOpt's automatic scan identifies all active technologies on the site, feeding the list of categories that must appear in the Cookies Policy.

The cookie notice configured through AdOpt blocks non-essential trackers before acceptance, presents categories with clear descriptions, offers real opt-out options, detects and honors the GPC from January 2025, processes revocations within 15 days, and logs every interaction.

Over 60,000 websites already run with AdOpt.

Privacy is not a banner. It is a position.

Want to build a Cookies Policy for your site that complies with the CTDPA? Talk to our team.

Visible link in the footer and within the cookie banner.

Listing of cookie categories with a description of what each does.

Specific purpose for each category, without vague descriptions (Section 6(c)(2)).

Identification of cookies constituting targeted advertising or sale (Section 6(d)).

Categories of third parties receiving data via cookies (Section 6(c)(5)).

Clear and conspicuous link for opt-out of targeted advertising/sale on the site (Section 6(e)(1)(A)(i)).

Opt-out preference signal: description of how GPC is honored from January 2025 (Section 6(e)(1)(A)(ii)).

15-day consent revocation: mechanism and deadline described (Section 6(a)(6)).

Non-essential cookies disabled by default, without dark patterns (Section 1(11)).

Protection for teens aged 13 to 15 described where applicable (Section 6(a)(7)).

Retention period for each cookie category.

Active email address or online mechanism for contacting the controller (Section 6(c)(6)).

Accessible language, without legal jargon.

No cookie walls.

1. Is the CTDPA opt-out link different from the CCPA's "Do Not Sell" link?
They are similar in function but different in requirement. The CCPA requires specific link texts: "Do Not Sell or Share My Personal Information" and "Limit the Use of My Sensitive Personal Information." The CTDPA simply requires a clear and conspicuous link to an opt-out page for targeted advertising or data sale, without mandating specific text. Businesses that already have the CCPA links likely satisfy the CTDPA requirement, depending on the link's scope.

2. Is the CTDPA's opt-out preference signal the same as the GPC?
The GPC is the best-known mechanism meeting the CTDPA's technical specifications. The law does not name the GPC specifically, but the GPC was developed precisely for this type of legal requirement. As long as the mechanism is an affirmative consumer choice (not a default), does not create unfair disadvantage for the controller, and allows verification that the consumer is a Connecticut resident, it meets Section 6(e)(1)(A)(ii).

3. Does the 15-day consent revocation deadline apply to all cookies?
It applies when consent is the basis for processing. For advertising cookies where the consumer gave consent and then revokes it, Section 6(a)(6) requires cessation within 15 days. For opt-outs of targeted advertising or sale (which do not require prior consent but rather an opt-out mechanism), the law does not specify the 15-day deadline, but requires cessation as soon as practicable.

4. Do analytics cookies constitute targeted advertising under the CTDPA?
It depends on the tool and configuration. If analytics data stays internal or is sent to the provider only to generate reports without use for targeting on other sites, it generally does not qualify. If the tool sends data used for targeting on other sites, it may. The CTDPA's criterion is data "obtained or inferred from activities across nonaffiliated websites" (Section 1(28)).

5. Does the CTDPA require teens aged 13 to 15 to consent before any cookie?
Section 6(a)(7) is specific: it prohibits processing data of 13-to-15-year-olds for targeted advertising or sale without their consent. It does not require consent for other types of processing such as internal analytics. The restriction applies when the controller has actual knowledge of the user's age.

Ready to build a Cookies Policy for your site that complies with the CTDPA? Talk to our team.