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ARTICLE · 06 MAY 2025

Religious Institutions Update: May 2025

Recent Federal Trade Commission (FTC) enforcement activity signals that companies need to protect consumer location data that could reflect sensitive locations...

United StatesEmployment and HR

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."

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