Federal Trade Commission · Announced 2024-04-15

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

    $5.1 million refund component plus $2 million civil penalty.

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.

Exercise your rights now

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The FTC order binds Cerebral, Inc.'s future practices, but doesn't automatically delete your existing data. State privacy law (CCPA, CPA, TDPSA, VCDPA) gives you that right. OfflistMe generates a compliant deletion email pre-addressed to Cerebral, Inc.'s registered privacy contact.

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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. paid $7,000,000 in monetary relief, 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.

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