Penalty Amount
$7,000,000
Consumers Affected
3,200,000
The FTC settled with telehealth firm Cerebral, Inc. for sharing sensitive consumer mental health data with third parties like LinkedIn, Snapchat, and TikTok for advertising without proper consent, employing sloppy security practices, and misleading consumers about cancellation policies. Cerebral must pay over $7 million (with $2 million due upfront), is permanently banned from using health information for most advertising, must implement a comprehensive privacy program, delete unnecessary data, and provide easy cancellation.
Cerebral must pay $7 million total ($5.1 million for consumer refunds and a $10 million suspended civil penalty after a $2 million payment). The company is permanently banned from using or disclosing personal and health information for most marketing/advertising without consent, must implement a comprehensive privacy and data security program, delete most consumer data not needed for treatment/payment/operations, provide an easy cancellation mechanism, post a corrective notice on its website, and face ongoing monitoring and reporting requirements.
In-house legal teams should review all vendor agreements where Cerebral shares data with third parties (e.g., LinkedIn, Snapchat, TikTok) for advertising, focusing on data sharing clauses and consent requirements. Customer agreements, including terms of service and privacy policies, must be examined for provisions on health data usage, advertising consent, cancellation policies, and data security standards. Data processing agreements should be checked for compliance with health data protection. Required changes include adding explicit opt-in consent for using health information in advertising, prohibiting such use entirely per the order, enhancing security measures, ensuring easy cancellation processes, and updating data retention and breach notification clauses to align with the settlement.
Entity
Cerebral, Inc.
Also known as: Cerebral
Industry
HealthcareOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/04/proposed-ftc-order-will-prohibit-telehealth-firm-cerebral-using-or-disclosing-sensitive-data
cerebral joint stipulation order permanent injunction
https://www.ftc.gov/system/files/ftc_gov/pdf/cerebral_joint_stipulation_order_permanent_injunction.pdf
2223087cerebralcomplaint
https://www.ftc.gov/system/files/ftc_gov/pdf/2223087cerebralcomplaint.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Cerebral, Inc. has agreed to an order"
"require it to pay $7 million"
"pay more than $7 million"
"disclosed consumers’ sensitive personal health information and other sensitive data to third parties for advertising purposes"
"failed to deploy adequate safeguards for the sensitive data collected from consumers and engaged in sloppy security practices"
"failed to clearly disclose all material terms of Cerebral’s cancellation policies before charging consumers"
The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.