The Federal Trade Commission (FTC) has been on a mission to get the message across that it is serious about companies collecting, using, and selling sensitive location data of consumers and that it is closely watching these practices.

On December 3, 2024, the FTC announced that it entered into a proposed order with Gravy Analytics and its subsidiary Venntel “for unlawfully selling location data tracking consumers to sensitive sites” and that the order “bans the use or sale of data associated with military sites, churches, labor unions and other sensitive locations.” Other locations noted include “religious organizations, correctional facilities, schools or childcare facilities, services supporting people based on racial and ethnic backgrounds, services sheltering homeless, domestic abuse, refugee or immigrant populations, and military installations.”

According to the press release, the proposed order requires Gravy Analytics and Venntel to implement a sensitive data location program, and they are prohibited from “selling, disclosing, or using sensitive location data in any product or service.” The FTC alleged in a complaint that Gravy Analytics “unfairly sold sensitive characteristics, like health or medical decisions, political activities and religious viewpoints, derived from consumers’ location data.”

The FTC alleged that Gravy Analytics “used geofencing, which creates a virtual geographical boundary, to identify and sell lists of consumers who attended certain events related to medical conditions and places of worship and sold additional lists that associate individual consumers to other sensitive characteristics.”

The proposed order requires the companies to delete all historic location data, unless the company obtains consent from consumers, or the data is “deidentified or rendered non-sensitive.”

The FTC noted that “this is [its] fourth action taken this year challenging the sale of sensitive location data, and it’s past time for the industry to get serious about protecting Americans’ privacy.” Message heard.