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.
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.
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.
Entity
Gravy Analytics Inc. and Venntel Inc.
Also known as: Gravy Analytics
Industry
Data BrokerOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/12/ftc-takes-action-against-gravy-analytics-venntel-unlawfully-selling-location-data-tracking-consumers
2123035gravyanalyticsorder
https://www.ftc.gov/system/files/ftc_gov/pdf/2123035gravyanalyticsorder.pdf
2123035gravyanalyticscomplaint
https://www.ftc.gov/system/files/ftc_gov/pdf/2123035gravyanalyticscomplaint.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Gravy Analytics Inc. and its subsidiary Venntel Inc."
"violated the FTC Act"
"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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