Cerebral, Inc., $7,000,000
Online mental-health service Cerebral disclosed sensitive patient information to third parties including LinkedIn, Snapchat, and TikTok and used dark patterns to make canceling subscriptions difficult.
Case identifiers
- Respondent
- Cerebral, Inc.
- Agency
- Federal Trade Commission
- Announced
- 2024-04-15
- Monetary relief
- $7,000,000
- Case number
- FTC File No. 232-3058
- Statutes cited
- FTC Act § 5 · Opioid Addiction Recovery Fraud Prevention Act
Key facts
- 1
Cerebral shared mental-health information including IP address, responses to mental-health questionnaires, diagnoses, and prescriptions with advertising platforms.
- 2
Data from ~3.2 million patients was disclosed to third parties between 2019 and 2023.
- 3
Used confusing sign-up flows and deceptive cancellation processes that made subscriptions hard to exit.
- 4
The proposed order required nearly $5.1 million for partial consumer refunds; a $10 million civil penalty was suspended after a $2 million payment because of Cerebral's inability to pay the full amount.
What the order requires
Injunctive terms imposed by the Federal Trade Commission. These bind Cerebral, Inc.'s data practices going forward.
- Permanent restriction on sharing health information with third parties for advertising.
- Required deletion of health information already disclosed.
- Implementation of data minimization and consumer consent practices.
- Simple one-click subscription cancellation.
Primary sources
Read the original government documents. These are the authoritative records, everything on this page is derived from them.
- Federal Trade Commission press releasehttps://www.ftc.gov/news-events/news/press-releases/2024/04/proposed-ftc-order-will-prohibit-telehealth-firm-cerebral-using-or-disclosing-sensitive-data
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Where this action sits in the tracker
- It is one of 19 FTC actions among the 26 cases in this tracker.
- Of the 19 tracked actions with monetary relief, $7,000,000 ranks number 9 by amount.
- 6 tracked actions were announced in 2024.
- It is one of 7 tracked health-data actions.
- It is one of 2 tracked mental-health actions.
- It is one of 1 tracked dark-pattern action.
FAQ
What did the FTC charge Cerebral, Inc. with?+
Online mental-health service Cerebral disclosed sensitive patient information to third parties including LinkedIn, Snapchat, and TikTok and used dark patterns to make canceling subscriptions difficult. The Federal Trade Commission cited FTC Act § 5, Opioid Addiction Recovery Fraud Prevention Act.
How much did Cerebral, Inc. pay?+
Cerebral, Inc. had monetary relief of $7,000,000, announced on 2024-04-15. The settlement also imposed injunctive terms (see below).
Does the Cerebral, Inc. settlement mean my data has been deleted?+
The order requires Cerebral, Inc. to delete certain categories of consumer data (see injunctive terms). Individual consumers should still exercise state-law deletion rights (CCPA, CPA, TDPSA) to confirm deletion from any remaining successor databases.
How can I read the original FTC order?+
The Federal Trade Commission press release is available at https://www.ftc.gov/news-events/news/press-releases/2024/04/proposed-ftc-order-will-prohibit-telehealth-firm-cerebral-using-or-disclosing-sensitive-data. The case / matter number is FTC File No. 232-3058.