Flo is a period, ovulation, and pregnancy tracking app run by Flo Health UK Limited (with affiliated entities in the US, Cyprus, Lithuania, and the Netherlands), headquartered in London with offices in Vilnius, San Francisco, and Amsterdam. A February 2019 Wall Street Journal investigation reported that the app was sending Facebook data every time a user logged a period or told the app she intended to get pregnant; the FTC's complaint states Flo stopped sharing with Facebook the day after the story ran. In June 2021 the FTC finalized a settlement alleging Flo had promised to keep users' health data private while sharing it, including the fact of a user's pregnancy, with outside marketing and analytics firms named as Facebook, Google, AppsFlyer, and Flurry; the order required affirmative consent before sharing health data, notice to affected users, destruction of the shared data by recipients, and an independent review of Flo's privacy practices. The same 2016-2019 sharing was then litigated as a class action: Google settled before trial, Flo settled on the eve of closing arguments (later agreeing to pay $8 million while denying the allegations), and on August 1, 2025 a federal jury in California found Meta violated the California Invasion of Privacy Act in collecting Flo users' reproductive health data, a verdict Meta disputes and the trial judge declined to overturn in September 2025. Since then Flo's current Privacy Policy states it does not sell personal data and will not use Apple HealthKit or Google Health Connect data for advertising, and in September 2022, after the Supreme Court overturned Roe v. Wade, the company launched 'Anonymous Mode,' an opt-in feature using Oblivious HTTP and post-quantum cryptography that decouples identity from health data, plus dual ISO 27001/27701 certifications. Period, pregnancy, and fertility data carries unusual stakes in the post-Roe United States; that is the context for these receipts, not a claim that any specific person was harmed through Flo data. Its Apple App Store privacy label nonetheless still discloses data used to track users across other companies' apps and a broad set of data categories linked to identity by default (non-Anonymous-Mode) use.
TRACK RECORD
5 ENFORCEMENT ACTIONS
[2021-06-22]
The FTC's case page for Matter 192-3133 (In the Matter of Flo Health, Inc.), last updated June 22, 2021 with Case Status 'Closed,' states Flo Health settled FTC allegations that it shared users' health information with outside data analytics providers after promising such information would be kept private.
The FTC's June 2021 press release finalizing the Flo Health order states the FTC alleged Flo shared sensitive health data from millions of users of its Flo Period & Ovulation Tracker app with marketing and analytics firms, including Facebook and Google, despite promising to keep the data private; the finalized settlement required Flo to notify affected users, instruct third-party recipients to destroy the data, and obtain both affirmative user consent before future health-data sharing and an independent review of its privacy practices.
The New York State Department of Financial Services' February 18, 2021 report on its investigation of Facebook's data practices (opened after the February 2019 Wall Street Journal article) records that Flo Health, a menstruation and fertility-tracking app used by more than 100 million consumers, sent Facebook data every time a user logged a period or told the app she intended to get pregnant, and sent data whenever the app was opened that told Facebook where the user was in her cycle ('ordinary', 'period', 'ovulation', or 'pregnant'); the report also notes the FTC's January 13, 2021 consent agreement with Flo.
The FTC's administrative complaint against Flo Health, Inc. (Matter 192-3133) alleges that Flo shared users' personal health information with third-party SDK providers for years while promising privacy, that it halted the sharing only in February 2019 when the Wall Street Journal revealed the practice (stopping the Facebook sharing the day after the exposé), that the Journal had intercepted unencrypted transmissions to Facebook containing a unique advertising identifier, the user's intention to get pregnant, and when the user was having her period, and that Flo received more than 300 user complaints after the story ran. These are the FTC's allegations, which Flo settled without admitting them.
The FTC's January 13, 2021 announcement of the proposed Flo Health settlement states that, despite promising to keep health data private, Flo disclosed health data from millions of users of its Flo Period & Ovulation Tracker app to third-party marketing and analytics providers, naming Facebook's analytics division, Google's analytics division, Google's Fabric service, AppsFlyer, and Flurry; that the disclosures took the form of 'app events' that included sensitive health information such as the fact of a user's pregnancy; that Flo did not limit how those third parties could use the data; and that Flo did not stop until a February 2019 news article revealed the practice, after which the settlement required Flo to notify affected users and instruct recipients to destroy the data.
Flo period-tracker data privacy settlement ($59.5M); claims due Oct. 15, 2026
You may be eligible if, at any time between November 1, 2016 and February 28, 2019, you lived in the United States and entered menstruation and/or pregnancy information into the Flo App.
Flo's Apple App Store privacy label lists a broad set of data categories 'Linked to You' by default, including Health & Fitness data, purchase history, coarse location, contact info (email address, name), search history, sensitive info, and user/device identifiers, used for purposes spanning the developer's advertising/marketing, analytics, product personalization, and app functionality; separately, Flo's Privacy Policy states that with consent it uses a user's device ID, age group, subscription status, and email 'to spread the word about Flo.'
UK Companies House's registry confirms FLO HEALTH UK LIMITED (company number 12898410) as an active private limited company incorporated on 23 September 2020, with its registered office at Fourth Floor, International House, 1 St. Katharines Way, London -- the same address given as the data controller's address in Flo's own Privacy Policy -- providing independent registry confirmation of the entity Flo names as controller.
Flo's Privacy Policy names Flo Health UK Limited as the company registered in the U.K. and the registered data controller of the Services, and separately names the wider corporate group involved in processing data: Flo Health Cyprus Ltd, Flo Health LTU UAB (Lithuania, Flo's main EU establishment), Flo Health NL B.V. (Netherlands), and Flo Health, Inc. (US).
Flo's Anonymous Mode page states that because the feature keeps identity and health data structurally unlinked, Flo would be unable to comply with a data request even if it received one -- the health data exists but there is no way for Flo to know it belongs to a particular user -- addressing the reproductive-health-specific concern that period-tracker data could reach law enforcement.
The FTC's January 2021 press release states that, per its complaint, Flo disclosed health data from millions of users of its Flo Period & Ovulation Tracker app to third parties that provided marketing and analytics services to the app -- including Facebook's analytics division, Google's analytics division, Google's Fabric service, AppsFlyer, and Flurry -- despite policy language promising that health data would be kept private and used only to provide the app's services. The FTC alleges Flo did not stop these disclosures until a February 2019 news report exposed the practice. Flo's proposed settlement required an independent review of its privacy practices and users' affirmative consent before future health-data sharing, without a finding that Flo violated the law.
Flo's own June 30, 2022 press release announcing Anonymous Mode states that while the feature had already been underway, its development was accelerated in the wake of the U.S. Supreme Court's ruling overturning Roe v. Wade, citing user concern about third parties accessing health data from digital services; it describes the mode as letting any of Flo's 240 million users use the service without a name, email address, or technical identifier tied to the account, and states that if Flo receives an official request to identify a user, Anonymous Mode would prevent Flo from connecting data to an individual.
Healthcare Dive reported that Flo launched Anonymous Mode on September 14, 2022, three months after the U.S. Supreme Court overturned Roe v. Wade, giving users the option to use the app without their name, email address, or technical identifiers associated with their health data, in partnership with Cloudflare so that no single party processing Anonymous Mode data has complete information on who the user is; Flo offers the mode as an option rather than the default because activating it means users cannot recover data if a device is lost and may lose personalization.
Flo's Privacy Policy (effective 9 April 2026) states Flo does not sell or rent personal data for money and will only share personal data as outlined in the policy, including with named infrastructure and communications service providers (Amazon Web Services, Cloudflare, Auth0/Okta, Elastic, Vercel, SendGrid/Twilio, Trustpilot, and others); it separately commits that data imported from Apple HealthKit or Google Health Connect will not be used for advertising or sold to advertising platforms, data brokers, or resellers.
Flo's Privacy Portal states Flo is 'the first and only period tracking app with dual ISO 27001 and ISO 27701 certifications,' with ISO 27001 (information security) achieved in 2022 and ISO 27701 (privacy management) achieved in 2024, both re-certified annually, describing the certifications as independent assessment of its security and privacy practices rather than self-reported claims -- the affirmative artifact behind this pillar's above-floor placement despite the 2021 FTC order.
The Wall Street Journal's February 22, 2019 investigation 'You Give Apps Sensitive Personal Information. Then They Tell Facebook.' (Sam Schechner and Mark Secada) reported, based on the Journal's own testing, that apps holding data such as users' menstrual cycles or pregnancy status were sharing that data with Facebook without users' knowledge; the FTC's complaint and the New York DFS report both identify Flo as one of the apps in that reporting and date Flo's halt of Facebook sharing to the day after publication. The archived page shows the headline, byline, date, and opening paragraphs; the full article is behind the Journal's paywall.
The FTC's administrative complaint against Flo Health, Inc. (Matter 192-3133) alleges that Flo shared users' personal health information with third-party SDK providers for years while promising privacy, that it halted the sharing only in February 2019 when the Wall Street Journal revealed the practice (stopping the Facebook sharing the day after the exposé), that the Journal had intercepted unencrypted transmissions to Facebook containing a unique advertising identifier, the user's intention to get pregnant, and when the user was having her period, and that Flo received more than 300 user complaints after the story ran. These are the FTC's allegations, which Flo settled without admitting them.
The FTC's January 13, 2021 announcement of the proposed Flo Health settlement states that, despite promising to keep health data private, Flo disclosed health data from millions of users of its Flo Period & Ovulation Tracker app to third-party marketing and analytics providers, naming Facebook's analytics division, Google's analytics division, Google's Fabric service, AppsFlyer, and Flurry; that the disclosures took the form of 'app events' that included sensitive health information such as the fact of a user's pregnancy; that Flo did not limit how those third parties could use the data; and that Flo did not stop until a February 2019 news article revealed the practice, after which the settlement required Flo to notify affected users and instruct recipients to destroy the data.
The New York State Department of Financial Services' February 18, 2021 report on its investigation of Facebook's data practices (opened after the February 2019 Wall Street Journal article) records that Flo Health, a menstruation and fertility-tracking app used by more than 100 million consumers, sent Facebook data every time a user logged a period or told the app she intended to get pregnant, and sent data whenever the app was opened that told Facebook where the user was in her cycle ('ordinary', 'period', 'ovulation', or 'pregnant'); the report also notes the FTC's January 13, 2021 consent agreement with Flo.
The FTC's case page for Matter 192-3133 (In the Matter of Flo Health, Inc.), last updated June 22, 2021 with Case Status 'Closed,' states Flo Health settled FTC allegations that it shared users' health information with outside data analytics providers after promising such information would be kept private.
The FTC's June 2021 press release finalizing the Flo Health order states the FTC alleged Flo shared sensitive health data from millions of users of its Flo Period & Ovulation Tracker app with marketing and analytics firms, including Facebook and Google, despite promising to keep the data private; the finalized settlement required Flo to notify affected users, instruct third-party recipients to destroy the data, and obtain both affirmative user consent before future health-data sharing and an independent review of its privacy practices.
The Record reported that on July 31, 2025 Flo settled with the class-action plaintiffs who alleged the app improperly shared millions of women's sensitive sexual and reproductive data with Meta and other third parties, settling on the eve of closing arguments and leaving Meta alone before the jury against what plaintiffs' lawyers described as a class of 38 million women; the suit alleged Flo told users it would not share the data but let Meta place an SDK in the app that received data about users' periods for targeted advertising, and followed the 2019 Wall Street Journal story and Flo's 2021 FTC settlement.
The Record (Recorded Future News) reported that on August 1, 2025 a federal jury in a California court found Meta violated the California Invasion of Privacy Act (CIPA) by covertly harvesting sensitive health data -- including whether a user was tracking her period -- that women shared with the Flo period-tracking app via an embedded Meta software development kit. The report notes the Federal Trade Commission had separately reached an agreement with Flo in 2021 requiring affirmative user consent before sharing health data going forward, that Google and the analytics platform Flurry had already settled with the plaintiffs before trial, and that Flo itself settled with plaintiffs the same day the article published. A Meta spokesperson said the company disagreed with the verdict and was exploring its legal options, and disputed that it wanted or used the health data at issue.
CNBC reported that a jury in the U.S. District Court for the Northern District of California found the plaintiffs proved Meta violated the California Invasion of Privacy Act, per a verdict form filed August 1, 2025, in the class action that began in 2021 against Flo Health, Meta, Google's parent Alphabet, and smaller analytics firms over Flo's sharing of reproductive health data through the defendants' SDKs; Google and one analytics firm settled before the July 2025 trial, Flo Health settled the day before the trial concluded, and Meta, which said it disagreed with the ruling and called the claims false, was expected to appeal.
Bloomberg Law reported that the August 1, 2025 San Francisco jury verdict for Flo users against Meta relied on the California Invasion of Privacy Act, a 1960s-era wiretapping law carrying a $5,000 penalty per violation; that with a certified class of California-based Flo users Meta itself has said damages could reach multiples of billions of dollars; that plaintiffs alleged Meta's SDKs embedded in the Flo app recorded users' answers about pregnancy goals and their last period without consent; and that Google settled before trial while Flo reached its agreement mid-trial (cited via an Internet Archive snapshot of the article, which is metered on the publisher's site).
The Record reported that on September 15, 2025 U.S. District Judge James Donato rejected Meta's bid to overturn the jury verdict (or obtain a new trial) finding Meta liable for using the Flo period-tracking app to obtain sensitive reproductive health data from millions of women, rejecting Meta's argument that the recordings were 'secondhand' and outside the California wiretapping law and finding the evidence 'amply supported' that Meta directly acquired users' communications with the Flo app in real time.
The Record reported on September 25, 2025 that, per court documents filed by the plaintiffs, Flo Health will pay $8 million and Google will pay $48 million (a fund for Flo users who entered menstruation or pregnancy information between November 2016 and the end of February 2019) to resolve the class action alleging the app illegally shared users' health data; both Flo and Google denied the allegations despite settling, and co-defendant Meta, which went to trial, was found liable by a jury in August.
Flo's Apple App Store privacy label states that Purchases, Location, Identifiers, and Usage Data collected by the app may be used to track users across apps and websites owned by other companies, i.e. cross-app/cross-site tracking is disclosed for default (non-Anonymous-Mode) use of the app.
Flo's Anonymous Mode page states the feature uses the Oblivious HTTP (OHTTP) protocol, specified in IETF RFC 9458, together with post-quantum cryptography, routing traffic through a relay so that no single party -- neither the relay nor Flo -- can see both a user's identity and their health data at the same time.