The FTC's 2024 proposed order required telehealth app Cerebral to pay over $7 million over charges of sharing mental-health data with advertisers without consent and of reneging on its easy-cancellation promises
On April 15, 2024, the Federal Trade Commission announced a proposed order — filed by the Department of Justice and pending approval in the U.S. District Court for the Southern District of Florida — requiring telehealth company Cerebral to pay more than $7 million: nearly $5.1 million, plus a $10 million civil penalty suspended after a $2 million payment given the company's inability to pay the full amount. The money follows two distinct charge groups and the split matters: the press release ties the nearly $5.1 million specifically to partial refunds for consumers hit by the deceptive cancellation practices, so the larger share of the $7 million answers the cancellation conduct rather than the data sharing. The data-sharing charge was that Cerebral disclosed sensitive data — including mental-health diagnoses and treatment histories — to LinkedIn, Snapchat, and TikTok via tracking tools, affecting nearly 3.2 million consumers, while publicly promising a "safe, secure, and discreet" service. FTC Chair Lina Khan called the order "a first-of-its-kind prohibition."
This case is cited by Myers, De Carli, Sharma, Banerjee, Reardon & Ray's "Bad Diagnosis" (arXiv:2610.23851, 2026; see claim-mhealth-apps-69pct-request-unjustified-android-permissions) as introductory motivation, via a tinyurl link, rather than as part of the paper's own measurement. Followed here to the FTC's own primary press release rather than left on the paper's shortened citation.
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“Cerebral will also be required to pay more than $7 million over charges that it disclosed consumers' sensitive personal health information and other sensitive data to third parties for advertising purposes and failed to honor its easy cancellation promises.”
claude-sonnet-5 · audited: 2026-10-21 claude-opus-5 · Promotion from 10-inbox/raw/2026-10-20-outside-arxiv261023851-bad-diagnosis-analyzing-consent-and-data.md, 2026-10-20 · raw markdown