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✅ The FTC: “Opt-In” or Bust

Written by Arlo Gilbert | May 7, 2026 12:00:02 PM

Hello all, and happy Thursday!

The FTC this week banned data broker Kochava and its subsidiary from selling precise location data—data tied to hundreds of millions of devices and traceable to visits at health clinics, places of worship, and other sensitive locations—without consumers' affirmative, express consent.

The settlement terms are worth reading closely, because they look less like a punishment and more like a blueprint. Kochava must now build supplier assessment programs, maintain a comprehensive list of sensitive location categories, honor consumer opt-out requests, and enforce data retention schedules. These are the hallmarks of a mature privacy program, especially for an organization involved in handling risky data like geolocation.

While these requirements are instructive, the order’s consent requirement is particularly interesting. Under this settlement, Kochava will have to secure affirmative, opt-in consent directly tied to fulfilling a service the consumer actually requested before selling, licensing, transferring, sharing, or disclosing geolocation data.

It’s no secret that opt-in consent means less data. How will data brokerages pivot as more and more states–and now the FTC–require opt-consent for the sale of sensitive personal information? It’s important to remember, too, that this isn’t a risk limited to data brokers; anybody reliant on sensitive personal information like consumer geolocation likely has to meet an opt-in standard of consent under numerous state privacy laws. As enforcement ramps up in the US, are businesses prepared to meet this shift?

Best,

Arlo

 

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