Precise location can reveal visits to medical facilities, places of worship and other sensitive locations. Recent FTC orders show that selling sensitive location data can trigger serious federal enforcement — but the exact legal theory matters.
The FTC Has Taken Concrete Action Against Location-Data Brokers
Recent FTC matters include final orders involving X-Mode/Outlogic, Mobilewalla, and Gravy Analytics/Venntel. The FTC alleged that these companies sold or used sensitive location information in ways that lacked appropriate consent or safeguards.
In May 2026, the FTC announced a proposed order resolving its Kochava litigation that would prohibit Kochava and its successor data-broker business from selling, licensing, transferring, sharing or disclosing sensitive location data unless the required affirmative express consent and other conditions are satisfied. The proposal arose from the FTC's 2022 lawsuit and should therefore be described as a proposed resolution, not as a final court judgment.
What "Sensitive Location Data" Can Reveal
FTC cases have identified location information capable of revealing visits to health facilities, places of worship, domestic-violence shelters, addiction-recovery facilities and other sensitive sites.
The important legal point is not that every GPS coordinate is automatically unlawful to collect or sell. The FTC's enforcement has focused on particular collection, consent, disclosure, deception and unfairness allegations.
Turn Off Unnecessary App Location Access
iPhone: go to Settings → Privacy & Security → Location Services, select an app and change its access. Where available, turn off Precise Location if the app does not need exact location.
Android: go to Settings → Location → App location permissions, select the app and choose the least access that still works for the feature. Android also allows approximate rather than precise location for supported apps.
These device settings control an app's access to device location; they do not by themselves erase location information already collected by a company or data broker.
What if the App Says Location Is Mandatory?
Do not assume that a refusal to provide location access automatically violates federal law. Whether a business can condition a service on location can depend on the service, its representations, state privacy laws, platform rules and the circumstances.
If the app claims location is technically necessary but appears to use it for unrelated advertising or data-broker purposes, save the wording, privacy policy, permission screen and any error message you receive.
What to Save Before Making a Complaint
- App permission screen.
- Privacy-policy language about location.
- Any statement about selling or sharing location data.
- Account or advertising settings showing your choices.
- Screenshots and dates.
- Any response from the developer or data broker.
Reporting Suspected Misconduct
If you believe a company is using or selling location data in a deceptive or unfair way, you can report the conduct to the FTC through ReportFraud.ftc.gov. California consumers may also have state privacy rights depending on the business and processing activity.
A complaint is strongest when it identifies the specific representation, permission, data practice or transaction and includes documentary evidence.
What This Means Practically
- Recent FTC orders make sensitive geolocation a serious enforcement issue.
- Turn off unnecessary precise/background access at the device level.
- Remember that stopping future access does not erase historical data.
- Do not claim that every location-based service must operate without location permission.
- Preserve the app's disclosures if you believe the practice is deceptive or unfair.
Related Kibbo Tools
Sources
- Federal Trade Commission — Kochava proposed order on sensitive location data, May 2026. ftc.gov
- Federal Trade Commission — Mobilewalla final order, January 2025. ftc.gov
- Federal Trade Commission — Gravy Analytics/Venntel final order, January 2025. ftc.gov
- Federal Trade Commission — X-Mode/Outlogic final order, April 2024. ftc.gov
- Apple Support — Control location information shared with apps. support.apple.com
- Google Android Help — Manage app location permissions. support.google.com