Penalty Amount
$7,000,000
Consumers Affected
3,200,000
The FTC settled with telehealth firm Cerebral, Inc. for sharing sensitive consumer mental health data with third parties like LinkedIn, Snapchat, and TikTok for advertising without proper consent, employing sloppy security practices, and misleading consumers about cancellation policies. Cerebral must pay over $7 million (with $2 million due upfront), is permanently banned from using health information for most advertising, must implement a comprehensive privacy program, delete unnecessary data, and provide easy cancellation.
Cerebral must pay $7 million total ($5.1 million for consumer refunds and a $10 million suspended civil penalty after a $2 million payment). The company is permanently banned from using or disclosing personal and health information for most marketing/advertising without consent, must implement a comprehensive privacy and data security program, delete most consumer data not needed for treatment/payment/operations, provide an easy cancellation mechanism, post a corrective notice on its website, and face ongoing monitoring and reporting requirements.
In-house legal teams should review all vendor agreements where Cerebral shares data with third parties (e.g., LinkedIn, Snapchat, TikTok) for advertising, focusing on data sharing clauses and consent requirements. Customer agreements, including terms of service and privacy policies, must be examined for provisions on health data usage, advertising consent, cancellation policies, and data security standards. Data processing agreements should be checked for compliance with health data protection. Required changes include adding explicit opt-in consent for using health information in advertising, prohibiting such use entirely per the order, enhancing security measures, ensuring easy cancellation processes, and updating data retention and breach notification clauses to align with the settlement.
Entity
Cerebral, Inc.
Also known as: Cerebral
Industry
HealthcareOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/04/proposed-ftc-order-will-prohibit-telehealth-firm-cerebral-using-or-disclosing-sensitive-data
cerebral joint stipulation order permanent injunction
https://www.ftc.gov/system/files/ftc_gov/pdf/cerebral_joint_stipulation_order_permanent_injunction.pdf
2223087cerebralcomplaint
https://www.ftc.gov/system/files/ftc_gov/pdf/2223087cerebralcomplaint.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Cerebral, Inc. has agreed to an order"
"require it to pay $7 million"
"pay more than $7 million"
"disclosed consumers’ sensitive personal health information and other sensitive data to third parties for advertising purposes"
"failed to deploy adequate safeguards for the sensitive data collected from consumers and engaged in sloppy security practices"
"failed to clearly disclose all material terms of Cerebral’s cancellation policies before charging consumers"
The FTC sent warning letters to 12 companies offering 'nudify' tools that generate nonconsensual intimate images, for failing to comply with the TAKE IT DOWN Act (TIDA) by not providing a mechanism for victims to request removal of such content. The letters urge immediate compliance with TIDA, which requires platforms to remove nonconsensual intimate images within 48 hours of a valid request. Noncompliant companies may face future legal action and civil penalties of up to $53,088 per violation.
The FTC began enforcing the TAKE IT DOWN Act on May 19, 2026, a law requiring covered platforms to establish a process for victims to request removal of nonconsensual intimate images and delete such content within 48 hours of a valid request. The agency launched a consumer complaint portal, issued compliance guidance for businesses and consumers, and sent reminder letters to major platforms including Meta, TikTok, and X about their obligations under the law. No specific penalties or enforcement actions against individual companies were announced in this release.
$6.5M
A federal court held Cliq Inc. and its executives Andrew Phillips and John Blaugrund in civil contempt for multiple violations of a 2015 FTC order requiring the payment processor to prevent enabling consumer fraud. The court found the defendants facilitated fraud by processing transactions for high-risk merchants, avoiding fraud monitoring, failing to conduct required underwriting, and ignoring chargeback thresholds. The court imposed $6.5 million in civil contempt sanctions against the defendants.
$795.8M
The FTC and State of Nevada settled charges with lead defendants of the IM Mastery Academy MLM scheme, including Chris and Isis Terry and their affiliated companies, over false earnings claims used to promote financial training programs and a multi-level marketing venture. The stipulated order imposes a $795.8 million judgment, with defendants surrendering nearly $90 million in assets including luxury real estate, vehicles, jewelry, and a yacht, totaling over $100 million with prior judgments from other involved defendants. The order also bans defendants from selling trading-training services, prohibits false earnings claims, and restricts deceptive practices including negative-option misrepresentations and telemarketing violations.
The FTC and State of Illinois, via the Department of Justice, filed a complaint against B.E.S.T. GDR LLC (d/b/a Premium Home Service) and its owner Yosef Bernath for creating thousands of fake home repair business listings with fabricated five-star reviews to deceive consumers. The defendants allegedly routed consumer calls to unqualified representatives, arranged for unlicensed technicians, and violated the FTC Act, Reviews and Testimonials Rule, Gramm-Leach-Bliley Act, and Illinois consumer protection laws. No monetary penalty has been imposed yet as the case is in initial filing stages.
Federal Trade Commission Chairman Andrew N. Ferguson sent letters to over a dozen major technology companies reminding them of their obligation to comply with the Take It Down Act (TIDA) by May 19, 2026. TIDA requires covered platforms to establish a process for victims, including children, to request removal of nonconsensual intimate images, with takedown of content and all identical copies required within 48 hours of a valid request. The FTC also issued supplemental guidance to help companies prepare for compliance and warned that it will monitor and enforce violations of the law.