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Consent DecreeLow Risk

FTC Bans Gravy Analytics from Selling Sensitive Location Data

Gravy Analytics Inc. and Venntel Inc.December 3, 2024Federal Trade Commission

Summary

The FTC took action against Gravy Analytics Inc. and Venntel Inc. for unlawfully tracking and selling sensitive consumer location data without consent. The proposed consent order prohibits the sale or use of sensitive location data, requires deletion of historic data, and mandates compliance programs. This is part of the FTC's series of actions against data brokers selling sensitive location data.

Remedy

The companies are banned from selling, licensing, or using sensitive location data except for national security or law enforcement. They must delete all historic location data and inform customers to delete or de-identify it. They must establish a sensitive location data program and a supplier assessment program to ensure consent, and are prohibited from making misrepresentations about their data practices.

Consent DecreeBanCompliance ProgramData DeletionCorrective NoticeAudit Requirement

Contract Impact

In-house legal teams should review all vendor agreements with data brokers or analytics providers, customer agreements involving location-based services, and data processing addendums (DPAs). Focus on clauses governing data sharing, consent requirements, data retention/deletion, and breach notification. Specific changes needed include: (1) explicitly prohibiting the sale, disclosure, or use of 'sensitive location data' (e.g., data tied to healthcare facilities, places of worship, military sites, labor unions); (2) mandating verifiable, opt-in consent for any collection or commercial use of location data; (3) requiring deletion of all historic sensitive location data; and (4) obligating vendors to establish a formal 'sensitive data location program' with internal compliance safeguards.

Contract Search Terms

sensitive location dataverifiable user consentdata retention schedulesensitive locations listdata processing addendumbreach notification clausedata sharing restrictionsconsumer consent mechanismdeletion of historic datacompliance program

Laws Cited

FTC Act

Violation Types

Entity Details

Entity

Gravy Analytics Inc. and Venntel Inc.

Also known as: Gravy Analytics

Industry

Data Broker

Official Sources

Source Evidence

Entity Name
"Gravy Analytics Inc. and its subsidiary Venntel Inc."
Laws Cited
"violated the FTC Act"
Violation description
"violated the FTC Act by unfairly selling sensitive consumer location data, and by collecting and using consumers’ location data without obtaining verifiable user consent"

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