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On December 3, 2024, the Federal Trade Commission announced proposed enforcement settlements involving Mobilewalla, Gravy Analytics, and its subsidiary Venntel. The agency alleged that the companies collected or sold sensitive location data without verifiable informed consent. The proposed orders would restrict these companies’ handling of sensitive location data, but the announcements did not establish a general ban on location-data sales or describe final court judgments.
Which companies did the FTC target?
The FTC announced two actions: one against Mobilewalla and a joint action against Gravy Analytics and Venntel. The agency’s allegations concerned location information that could expose visits to health facilities, reproductive-health sites, places of worship, military installations, unions, schools, shelters, and other sensitive places.
The Commission said that collecting or selling such information without verifiable informed consent, and without adequate anonymization, could expose people to stigma, discrimination, violence, and emotional distress. These were allegations in administrative complaints, not findings from a completed court trial.
How the alleged data collection differed
| Company or companies | Alleged data source and practices | Scale stated in the FTC materials |
|---|---|---|
| Mobilewalla | The complaint alleged that the company collected real-time-bidding information, including bid-request data even when it did not win the advertising auction. It allegedly sold raw location data to advertisers, data brokers, and analytics firms, and created audiences such as women who had visited pregnancy centers. | The complaint alleged that Mobilewalla collected more than 500 million unique consumer advertising identifiers paired with precise location data from January 2018 through June 2020. |
| Gravy Analytics and Venntel | The companies allegedly obtained location information from other suppliers. The FTC said Gravy used geofencing to create lists of people who attended events associated with medical conditions or worship, and that the companies sold data that could identify consumers. The complaint also described sensitive characteristics such as health decisions, political activity, and religious viewpoints. | The companies said they collected, processed, and curated more than 17 billion signals from around one billion mobile devices daily. This was the companies’ stated scale, not a separate FTC measurement of unique people. |
The complaints described data that could be linked to individuals or devices and used to infer sensitive activities. The FTC said the companies had not adequately ensured that people understood and consented to the relevant collection or use.
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Did the FTC ban the sale of location data?
No blanket ban was announced. The proposed orders would impose restrictions on the named companies, prohibiting them from selling, licensing, transferring, sharing, disclosing, or using sensitive location data. The Gravy Analytics and Venntel proposal included limited exceptions described for national-security or law-enforcement purposes. The announcements do not establish that every kind of location data, or every data broker’s activity, was prohibited.
The proposals also would require steps intended to limit how sensitive information enters and remains in the companies’ systems:
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- Assess suppliers and verify that required consumer consent was obtained.
- Create programs to identify and protect data associated with sensitive locations.
- Delete or de-identify historic data covered by the orders.
- Notify certain prior customers about the orders.
- Provide mechanisms for consumers to request deletion or withdraw consent.
- Maintain comprehensive privacy programs.
Were the penalties final?
No. The December 3 announcements described proposed administrative settlements. The FTC said the agreements would be published in the Federal Register for a 30-day public-comment period, after which the Commission would decide whether to make the orders final. They were not described in the releases as final court judgments, and the releases did not announce consumer payouts or negotiated monetary settlement amounts.
In the FTC’s explanation, an administrative complaint is issued when the agency has “reason to believe” a law has been or is being violated and that a proceeding is in the public interest. If finalized, a consent order has the force of law for future conduct; violating a final order can expose a company to civil penalties. That potential consequence is distinct from a penalty already imposed in these proposed agreements.
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