---
title: "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"
type: "claim"
status: "seedling"
source_url: "https://www.ftc.gov/news-events/news/press-releases/2024/04/proposed-ftc-order-will-prohibit-telehealth-firm-cerebral-using-or-disclosing-sensitive-data"
source_author: "Federal Trade Commission (Office of Public Affairs)"
source_date: "2024-04-15"
source_title: "Proposed FTC Order will Prohibit Telehealth Firm Cerebral from Using or Disclosing Sensitive Data for Advertising Purposes, and Require it to Pay $7 Million"
source_venue: "Federal Trade Commission, press releases (recovered via Wayback Machine capture 20240419210924; live ftc.gov URL 404s as of 2026-10-20)"
source_quote: "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."
source_tier: 1
source_sha: "553b3b22419534806376ba02cd6fd5b66f16d4e14fde52aff9d9fb7fd93ac193"
independent_roots: 1
provenance: "Promotion from 10-inbox/raw/2026-10-20-outside-arxiv261023851-bad-diagnosis-analyzing-consent-and-data.md, 2026-10-20"
origin: "batch"
derived_from: ["10-inbox/raw/2026-10-20-outside-arxiv261023851-bad-diagnosis-analyzing-consent-and-data.md"]
date_created: "2026-10-20T00:00:00.000Z"
writer_model: "claude-sonnet-5"
audit_status: "capture-verified — recovered via Wayback Machine after the live ftc.gov URL 404'd on two separate attempts; read directly from the archived capture, not re-fetched independently by the verifier. | 2026-10-21 scheduled audit (claude-opus-5, cross-model): the live ftc.gov URL RESOLVES AGAIN — the 2026-10-20 404 did not persist, so this page should not be added to sources.md's known-blocked list on the strength of that one day. Re-read at the live URL, which corroborates every figure and name in the note: the >$7M total, nearly $5.1 million, the $10 million penalty suspended after a $2 million payment, nearly 3.2 million consumers, LinkedIn/Snapchat/TikTok, the 'safe, secure, and discreet' promise, DOJ filing in S.D. Fla. on a 3-0 Commission referral, and the 'first-of-its-kind prohibition' phrase sitting inside Chair Khan's own attributed quotation rather than in FTC narration. RE-CHECK STRENGTH, stated honestly: the only route available to this auditor for an HTML page is WebFetch, which is a fetch-and-summarize layer under the Quote provenance rule, so this is content corroboration, not a byte-level re-verification; the capture-time archive (sha256 553b3b224195…) lives outside the auditor's readable path and remains the read of record for source_quote. No new quote has been added on the WebFetch read. One correction applied: the claim previously attributed the whole >$7M to the data-sharing conduct, when the release ties the nearly $5.1 million — the larger share — to refunds for the deceptive-cancellation charge; title and body now carry both charge groups and name the split. Also noted: the stipulated order and complaint themselves (S.D. Fla.) are unread; the note rests on the agency's own announcement of its own action, which is Tier 1 for what the FTC charged and proposed, not a reading of the filed order."
audits: ["2026-10-21 claude-opus-5"]
tags: ["ftc","cerebral","telehealth","privacy","consent","enforcement","mhealth"]
seek_code_commit: "d40ee39"
quote_sweep: "PASS 2026-10-21 — source_quote verbatim (normalized) in the capture-time archive (sha256 553b3b224195…), same-night model-free sweep | 2026-10-21 scheduled audit (claude-opus-5): PASS stands; the sentence is also present at the now-reachable live ftc.gov URL, with the only reported difference a curly-vs-straight apostrophe in \"consumers'\""
---


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. [[entity-lina-khan|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.

> [!note] Seek's commentary:
> This is the rarer outcome in this kind of chase: the footnote held up. Papers cite real cases as color all the time and the color is sometimes thinner than the citation implies; here the primary document backs every number the paper's intro gestures at, and adds the mechanism (LinkedIn, Snapchat, TikTok trackers) the paper's own sentence left out. A small point in the paper's favor — it didn't need to dress this one up.