Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

FTC Settles with Data Brokers Over Unlawful Sale of Sensitive Location Data 

By Elizabeth Ignowski & Noreen Vergara on March 12, 2026
Email this postTweet this postLike this postShare this post on LinkedIn

This post is part of our The Top 2025 Privacy and Security Issues Still Shaping Healthcare series, in which our team of attorneys provides essential strategies and insights for healthcare privacy and security.

In December 2024, the FTC announced two separate settlements against Mobilewalla, Inc. and Gravy Analytics, Inc., asserting that the two companies were unlawfully tracking and selling sensitive location data from users without consent, including data related to visits to health centers. 

  • Mobilewalla was additionally accused of using sensitive location data to develop audience segments and then selling that information to its clients so they could target specific consumers for advertising. One reported audience segment was pregnant women, identified through tracking data from pregnancy center visitors. 
  • Gravy Analytics was accused of collecting and using sensitive consumer location data without informed consent, as well as selling data based on health-related characteristics. They were also alleged to have geofenced medical events and sold the resulting data. 
  • Both companies were prohibited from selling, disclosing, or using sensitive location data from health clinics specifically, as well as other locations related to protected status (e.g., religious institutions, labor union offices, etc.). 

As part of the settlements, both companies are prohibited from selling, disclosing, or using sensitive location data obtained from visits to health clinics. The restrictions also extend to data collected from other locations associated with protected status, including religious institutions and labor union offices. These prohibitions represent a significant enforcement action in the ongoing effort to protect consumer privacy. 

Why these settlements are interesting and relevant 

  • They restrict the sale of private and health-related geolocation data that isn’t subject to HIPAA. 
  • Many consumer behaviors, when aggregated and analyzed, can reveal all kinds of information about the specific consumer, including health status. 
  • This occurred under the previous administration, so it remains to be seen how, or if, the new administration’s FTC will handle similar cases. 

Restrictions on Geolocation Data Sales 

The recent settlements are notable because they impose strict limitations on the sale of private and health-related geolocation data even when such data is not subject to HIPAA regulations. By narrowing what information can be collected and monetized, they are a response to growing concerns over consumer privacy in the digital age. 

Aggregating and analyzing consumer behaviors can unveil sensitive insights about individuals, including their health status. For example, analyzing location data patterns has previously enabled companies to infer highly personal information based on purchasing habits. 

It is important to recognize that these settlements were reached under the previous executive administration. As a result, there is uncertainty about how the new FTC will approach similar matters. The handling of such cases going forward remains to be seen.

Contact us

For further details or additional information, please contact Noreen Vergara or another member of the Husch Blackwell Healthcare Privacy and Security Work Group.

Photo of Elizabeth Ignowski Elizabeth Ignowski

Liz helps clients navigate complex legal and policy issues in the health industry.

Read more about Elizabeth IgnowskiEmail
Photo of Noreen Vergara Noreen Vergara

As a Healthcare Regulatory Attorney and former executive, Noreen is a transparent communicator and innovative problem solver with a deep background in operations and risk management.

Noreen’s career in healthcare operations, healthcare compliance and executive leadership began as a behavioral health admissions representative

…

As a Healthcare Regulatory Attorney and former executive, Noreen is a transparent communicator and innovative problem solver with a deep background in operations and risk management.

Noreen’s career in healthcare operations, healthcare compliance and executive leadership began as a behavioral health admissions representative – she understands the day-to-day regulatory hurdles facing healthcare clients. Most recently, Noreen served as Acting CEO, General Counsel and Chief Human Resources Executive for a national managed behavioral health venture with employees across 50 states. In this position, Noreen leveraged her experience in strategic planning, corporate governance, complex contracts, employment law and compliance. Noreen navigated tough decisions including guiding 500 percent growth over 6 years, moving online quickly during COVID-19 and helping secure the largest contract in company history. Earlier in her career, Noreen collaborated in-house at the National Association of Insurance Commissioners (NAIC), where oversight, peer review, best practices and standards are established by state regulators.

Read more about Noreen VergaraEmailNoreen's Linkedin Profile
Show more Show less
  • Posted in:
    Health Care and Life Sciences, Privacy and Cybersecurity
  • Blog:
    Healthcare Law Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo