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On December 3, 2024, the Federal Trade Commission announced enforcement actions against Mobilewalla, Gravy Analytics and its subsidiary Venntel. The proposed orders would restrict the companies’ handling of sensitive location data and require changes to consent checks, data retention and consumer controls. They were proposed administrative settlements—not final court judgments—and did not announce payments to consumers.
What the FTC alleged
The FTC’s complaints focused on precise location information that could reveal visits to places such as health and reproductive-health facilities, places of worship, military installations, unions, schools and shelters. The agency alleged that the companies collected or sold location data without verifiable informed consent and that the data was not adequately anonymized.
Location trails can expose more than a person’s whereabouts. When tied to an identifiable device or consumer, visits to sensitive places can suggest health decisions, religious practice or other personal characteristics. The FTC said this kind of disclosure could expose people to stigma, discrimination, violence or emotional distress. Those are allegations in the agency’s complaints, not findings from final judgments.
Which companies were targeted, and what did the FTC say they did?
Mobilewalla was the subject of one action. Gravy Analytics and Venntel were addressed together in a separate action. The complaints describe different routes by which location data entered the brokers’ systems and different alleged uses.
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| Company | Alleged data source or practice | Scale stated by the FTC |
|---|---|---|
| Mobilewalla | The complaint alleged that it collected information from real-time advertising bid requests, including requests for auctions it did not win, then sold raw location data to advertisers, data brokers and analytics firms. The FTC also alleged that it created audience groups, including women who had visited pregnancy centers. | The complaint alleged collection of more than 500 million unique consumer advertising identifiers paired with precise location data from January 2018 through June 2020. |
| Gravy Analytics and Venntel | The FTC said the companies obtained location information from other suppliers and sold data that could identify consumers. The complaint alleged geofencing and the sale of lists associated with medical conditions and places of worship; it also implicated sensitive characteristics such as health decisions, political activity and religious viewpoints. | The companies claimed to collect, process and curate more than 17 billion signals from around one billion mobile devices daily. This is the companies’ claimed scale, as reported by the FTC, not an independent FTC measurement. |
The FTC’s account of Mobilewalla’s bid-request collection is distinct from the Gravy Analytics and Venntel allegations about information obtained from suppliers. The joint Gravy/Venntel release specifically described Gravy’s use of geofencing to build lists of people attending events connected with medical conditions or worship; it should not be read as establishing that every alleged practice applied identically to both companies.
Did the FTC ban the sale of location data?
Not through these December 2024 announcements alone. The proposed orders would prohibit the companies from selling, licensing, transferring, sharing, disclosing or using sensitive location data, subject to limited national-security or law-enforcement exceptions described for Gravy Analytics and Venntel. The restrictions were proposed company-specific remedies, not a general new ban covering every data broker.
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The orders also proposed requirements intended to address how data enters and remains in the companies’ systems:
- Establish programs for identifying and protecting sensitive location data.
- Assess suppliers and verify that location data was collected with appropriate consent.
- 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 FTC described the agreements as proposed administrative settlements. Under the process set out in the agency’s releases, the proposals would be published in the Federal Register for 30 days of public comment, after which the Commission would decide whether to make the orders final.
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An FTC administrative complaint means the agency has “reason to believe” the law has been or is being violated and that a proceeding is in the public interest. It is not itself a final determination that the allegations are true. If finalized, a consent order carries the force of law for future conduct; violating a final order can lead to civil penalties. The December announcements did not specify a negotiated monetary settlement amount or a consumer payout.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What this means for consumers
The proposed consumer-facing controls would give people a way to request deletion or withdraw consent from the covered companies. But the announcements do not establish that consumers automatically receive compensation, that every copy held by every downstream recipient would be removed, or that the proposed orders had already taken effect when announced. Their practical reach depends on the final orders and on compliance with their terms.
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The cases also illustrate why app permissions alone may not describe every path through which location information can travel. The FTC’s Mobilewalla complaint described collection from advertising bid requests, while the Gravy Analytics and Venntel release described information obtained from suppliers. The alleged practices concern brokers and data flows beyond a simple account of an individual app’s location setting.
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