Penalty Amount
$2,500,000
Consumers Affected
84,000
Monument, Inc., an alcohol addiction treatment firm, shared consumers' health data with third-party advertising platforms like Meta and Google without consent, despite promising confidentiality. The FTC settled with a consent order that bans Monument from disclosing health data for advertising, requires affirmative consent for other sharing, imposes a $2.5 million suspended fine, and mandates data deletion, consumer notification, and a privacy program.
Monument is banned from disclosing health information for advertising and must obtain affirmative consent before sharing health information for any other purpose. The company must pay a $2.5 million civil penalty (suspended), delete user data shared with third parties, notify affected consumers, and implement a comprehensive privacy program with data retention limits.
In-house legal teams should review all agreements involving consumer health data, particularly vendor contracts with advertising platforms (e.g., Meta, Google), customer Terms of Service/Privacy Policies, and Data Processing Agreements (DPAs). Specific clauses to scrutinize include: (1) data sharing and licensing provisions to ensure they explicitly prohibit using sensitive health information for advertising/targeting; (2) consent mechanisms to verify they require clear, affirmative, and separate consent for any health data sharing beyond core service delivery; (3) confidentiality and data security clauses to align with promised protections; and (4) audit and compliance reporting requirements. Changes needed will likely involve adding explicit bans on using health data for ads, implementing granular consent flows, strengthening data deletion protocols, and mandating regular privacy program assessments and reporting.
Entity
Monument, Inc.
Also known as: Monument
Industry
HealthcareOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/04/alcohol-addiction-treatment-firm-will-be-banned-disclosing-health-data-advertising-settle-ftc
MonumentOrderFiled
https://www.ftc.gov/system/files/ftc_gov/pdf/MonumentOrderFiled.pdf
MonumentComplaintFiled
https://www.ftc.gov/system/files/ftc_gov/pdf/MonumentComplaintFiled.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"New York-based Monument, Inc."
"imposes a $2.5 million civil penalty"
"FTC Act’s prohibition against unfair and deceptive practices"
"Opioid Addiction Recovery Fraud Prevention Act of 2018 (OARFPA)"
"FTC says Monument shared consumers’ health data with third-party advertising platforms without consent"
The FTC rescinded its 2021 Policy Statement on Breaches by Health Apps and Other Connected Devices, which had purported to apply the Health Breach Notification Rule to health apps and connected devices that collect consumer health information. The rescission follows the Commission's 2024 update to the Health Breach Notification Rule, which already covers health apps and connected devices like fitness trackers, and implements an executive order directing agencies to eliminate obsolete guidance documents. No company was charged or penalized; this is a deregulatory action.
$12.0M
The FTC alleged that payment processor Humboldt Merchant Services knowingly processed payments for more than 1,000 shell merchant entities serving as fronts for fraudulent companies engaged in unauthorized billing scams, despite red flags including chargeback rates nearly 10 times higher than card-brand thresholds. Under the proposed stipulated order filed in the U.S. District Court for the Eastern District of Michigan, Humboldt will pay $12 million for consumer redress and is permanently banned from processing payments for merchants with a heightened risk of potential fraud.
$4.8M
The FTC charged Canada-based payment processor Nuvei Corporation and its subsidiaries with knowingly processing payments for fraudulent merchants, including more than $30 million in payments for the Reimage tech support scam from 2017 to 2023, as well as merchants making false earnings claims and impersonating government tax authorities. Under the stipulated order filed in the U.S. District Court for the District of Arizona, Nuvei will pay $4.85 million for consumer redress, is banned from serving tech support telemarketers, and must implement robust merchant screening and chargeback monitoring practices. Note: this is a payments-fraud facilitation action under the FTC Act and Telemarketing Sales Rule, not a data privacy violation.
The FTC announced a seven-day extension of the public comment period on its proposed enforcement policy statement regarding personalized pricing, pushing the deadline from Sept. 18, 2026 to Sept. 25, 2026. Personalized pricing refers to using personal data to set prices based on what the company believes an individual consumer is willing to spend. This is a procedural announcement about draft agency guidance, not an enforcement action against any company, and no entity was named, no violation found, and no penalty imposed.
Colorado Attorney General Phil Weiser joined the FTC and 22 state attorneys general in filing a lawsuit against Amazon for manipulating the auctions used to set advertising prices, replacing actual auction results with higher prices since 2019 and overcharging nearly 1.2 million U.S. advertising customers. The FTC estimates total improper surcharges from 2018 to 2026 exceed $20 billion, with costs ultimately passed to shoppers through higher prices. The states seek a permanent injunction and monetary relief; no penalty has been imposed yet as this is a newly filed complaint.
$930K
The FTC finalized orders requiring CMG Media Corporation (doing business as Cox Media Group), MindSift LLC, and 1010 Digital Works LLC to pay a total of $930,000 for falsely claiming they offered an AI-powered service that could target ads based on conversations captured from consumers' smart devices, and that consumers had opted into such targeting. The orders also prohibit the companies from making misrepresentations about their advertising services, voice data collection, and consumer consent.