Key Cases
Privacy
Federal Trade Commission Protects Worship Location
Data
Shannon Britton Hartsfield and Bess Hinson-Greenspan
Recent Federal Trade Commission (FTC) enforcement activity
signals that companies need to protect consumer location data that
could reflect sensitive locations, including the consumer's
place of worship. The FTC views consumer location data as
information that must be protected, particularly when it signals
that an individual visits a church or similar locations. In January
2025, the FTC finalized two separate orders relating, in part, to
this type of data.
Complaint Against Gravy Analytics and Venntel
One order resulted from a complaint against Gravy Analytics and
its subsidiary Venntel. The FTC's complaint alleged that these
companies acted unfairly and in violation of the FTC Act by selling
sensitive location data and collecting and using such data
"without obtaining verifiable consent for government and
commercial uses."